Deadline 20 January 2012 12:00 CET...Deadline 20 January 2012 12:00 CET will decrease the overview of the Balance sheet. BS-C1- cell L6C Technical Provisions should not be divided

Template comments 1/149

Comments Template on

Draft proposal for Quantitative Reporting Templates

Deadline

20 January 2012

12:00 CET

Name of Company: Federation of Finnish Financial Services

Disclosure of comments: Please indicate if your comments should be treated as confidential: Public

Please follow the following instructions for filling in the template:

Do not change the numbering in the column “reference”; if you change

numbering, your comment cannot be processed by our IT tool

Leave the last column empty.

Please fill in your comment in the relevant row. If you have no comment on a

paragraph or a cell, keep the row empty.

Our IT tool does not allow processing of comments which do not refer to the

specific numbers below.

o Certain rows represent a group of cells with similar information (ex : TP

- E3- cells A17-A31-J16 for a given triangle in TP-E3)

o Cells that refer to formulas are not mentioned in specific rows; in case

you have comments on formulas, please make them in the cell

“general” for the given template

o In spreadsheets & LOGs, certain cell number may seem like they are

missing (ex : going directly from cell B1 to cell B3); this is normal, as

they may refer to a previously existing cell that has been deleted during

informal consultations, and cell numberings have not been changed for

interal consistency purposes

o If your comment refers to multiple cells or paragraphs, please insert

your comment at the first relevant paragraph and mention in your

comment to which other cells or paragraphs this also applies.

o If your comment refers to subparagraphs or specific cells within a

group, please indicate this in the comment itself.

Please send the completed template, in Word Format, to

[email protected]. Our IT tool does not allow processing of any other

mailto:[email protected]




Deadline

20 January 2012

12:00 CET

formats.

The numbering of the paragraphs refers to this Consultation Paper, the numbering of

cells refers to the accompanying spreadsheets and LOGs, the reference to “General”,

“Purpose”, etc. refers to summary documents.

Reference Comment

General Comment Articles on which the reports are based would be clarifying. The sign notation has not been properly specified in the templates. It would be easier

e.g. for checking purposes to specify

+ into the undertaking and

– from the undertaking.

It would be appreciated if changes to these templates would be somehow shown by EIOPA, Because undertakings will start doing definitions to their system based on these templates (which are consulted now).

3.1

3.2

3.3

3.4

3.5

3.6

4.1

4.2

4.3




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4.4

4.5

4.6

4.7

4.8

4.9

4.10

4.11

Technical Annex (only for

insconsistencies)

BS-C1 – General Regarding field A16 (Not found in the comment template.): Should cell A20 (Reinsurance receivables) really be included in the sum showed in this field? It is not in line with reinsurance report J3 cell N1 (Total reinsurance recoverables).

BS-C1 – Purpose

BS-C1 – Benefits

BS-C1 – Costs

BS-C1 – Groups

BS-C1 – Materiality

BS-C1 - Disclosure

BS-C1 – Frequency We see a need to report the Balance sheet on quarterly basis as it is needed to report the OF report. It also adds value to the data quality verification.

BS-C1 – cell AS1

BS-C1- cell AS24

BS-C1- cell A2

BS-C1- cell AS2




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BS-C1- cell A26

BS-C1- cell AS26

BS-C1- cell A25B

BS-C1- cell AS25B

BS-C1- cell A3

BS-C1- cell AS3

BS-C1- cell A5

BS-C1- cell AS5

BS-C1- cell A6

BS-C1- cell AS6

BS-C1- cell A7 No split should be made between listed and unlisted – too many details will decrease the overview of the Balance sheet.

BS-C1- cell AS7 No split should be made between listed and unlisted – too many details will decrease the overview of the Balance sheet.

BS-C1- cell A7A No split should be made between listed and unlisted – too many details will decrease the overview of the Balance sheet.

BS-C1- cell AS7A No split should be made between listed and unlisted – too many details will decrease the overview of the Balance sheet.

BS-C1- cell A8 No split should be made between government and corporate bonds – too many details will decrease the overview of the Balance sheet.

BS-C1- cell AS8 No split should be made between government and corporate bonds – too many details will decrease the overview of the Balance sheet.

BS-C1- cell A8A No split should be made between government and corporate bonds – too many details will decrease the overview of the Balance sheet.

BS-C1- cell AS8A No split should be made between government and corporate bonds – too many details will decrease the overview of the Balance sheet.

BS-C1- cell A8C

BS-C1- cell AS8C

BS-C1- cell A8D

BS-C1- cell AS8D




Deadline

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12:00 CET

BS-C1- cell AS9

Comment to A9A- A9F: This classification results in additional work because of the level of detail and it will not provide a transparent Balance Sheet from the reader’s point of view. Does this need to be specified in the Balance Sheet? The information which is requested here will be gathered by calling/contacting each fund company where we have our holding in. Then the fund companies must estimate each fund which means that the figures will not be reliable during the reporting period. Correct amounts will be with one-quarter drop. Another issue which is very unclear with this reporting is how we should deal with the currency effects when for example we have a fund booked in EUR but the underlying instruments are in a couple of different currencies. How can you break down this fund into the underlying instruments in accounting? How should the currency issue be handled/reported?

In purpose column it would be better to say Assets – D4 report as in other guidelines of other cells in order not to wonder what D4.

BS-C1- cell AS9A

BS-C1- cell AS9B

BS-C1- cell AS9C

BS-C1- cell AS9D

BS-C1- cell AS9E

BS-C1- cell AS9F

BS-C1- cell A10A

BS-C1- cell AS10A

BS-C1- cell A10B

BS-C1- cell AS10B

BS-C1- cell A14

A14 is Loans & mortgages (except loans on policies) in assets side. There is also the

field AS14 (Other technical provisions) in the liability side – is this really correct?

Shouldn’t it be LS14 on liability side instead?




Deadline

20 January 2012

12:00 CET

Other technical provisions is to be disclosured only in statutory accounts value, it must

cover e.g. equalisation provision/ reserve, mustn’t it?

BS-C1- cell AS14

BS-C1- cell A11

BS-C1- cell AS11

BS-C1- cell A12

BS-C1- cell AS12

BS-C1- cell A14A

BS-C1- cell AS14A

BS-C1- cell A17

A17-A19A: Reinsurance recoverable should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet.

BS-C1- cell AS17

Reinsurance recoverable should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet.

BS-C1- cell A18


BS-C1- cell AS18


BS-C1- cell A18A


BS-C1- cell AS18A


BS-C1- cell A19


BS-C1- cell AS19


BS-C1- cell A19A


BS-C1- cell AS19A

BS-C1- cell A13




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BS-C1- cell AS13

BS-C1- cell A21

BS-C1- cell AS21

BS-C1- cell A20

BS-C1- cell AS20

BS-C1- cell A23

BS-C1- cell AS23

BS-C1- cell A27

BS-C1- cell AS27

BS-C1- cell A29

BS-C1- cell AS29

BS-C1- cell LS1

Technical Provisions should not be divided between life, non-life and health – too many details will decrease the overview of the Balance sheet.

BS-C1- cell L1A


BS-C1- cell L2


BS-C1- cell L3


BS-C1- cell LS4


BS-C1- cell L4A


BS-C1- cell L5


BS-C1- cell L6


BS-C1- cell LS6B Technical Provisions should not be divided between life, non-life and health – too many details




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will decrease the overview of the Balance sheet.

BS-C1- cell L6C


BS-C1- cell L6D


BS-C1- cell L6E


BS-C1- cell LS7


BS-C1- cell L7A


BS-C1- cell L8


BS-C1- cell L9


BS-C1- cell LS10


BS-C1- cell L10A


BS-C1- cell L11


BS-C1- cell L12


BS-C1- cell L23

BS-C1- cell L18

BS-C1- cell LS18

BS-C1- cell L22

BS-C1- cell LS22

BS-C1- cell L13




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BS-C1- cell LS13

BS-C1- cell L17

BS-C1- cell LS17

BS-C1- cell L16

BS-C1- cell LS16

BS-C1- cell L19

BS-C1- cell LS19

BS-C1- cell L20

BS-C1- cell LS20

BS-C1- cell L15A

BS-C1- cell LS15A

BS-C1- cell L15B

BS-C1- cell LS15B

BS-C1- cell L15C

BS-C1- cell LS15C

BS-C1- cell L15D

BS-C1- cell LS15D

BS-C1- cell L25

BS-C1- cell LS25

BS-C1- cell L26

BS-C1B – General

BS-C1B – Purpose

BS-C1B – Benefits

BS-C1B – Costs

BS-C1B – Groups




Deadline

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12:00 CET

BS-C1B – Materiality

BS-C1B - Disclosure

BS-C1B – Frequency

BS-C1B- cell A2

BS-C1B- cell A3A

BS-C1B- cell A3C

BS-C1B- cell B3C

BS-C1B- cell C3C

BS-C1B- cell D3C

BS-C1B- cell A3B

BS-C1B- cell B3B

BS-C1B- cell A10

BS-C1B- cell B10

BS-C1B- cell A12A

BS-C1B- cell B12A

BS-C1B- cell A13

BS-C1B- cell B13

BS-C1B- cell A13A

BS-C1B- cell B13A

BS-C1B- cell A14

BS-C1B- cell B14

BS-C1B- cell A15A

BS-C1B- cell B15A

BS-C1B- cell A17

BS-C1B- cell B17

BS-C1B- cell A17A




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BS-C1B- cell B17A

BS-C1B- cell A18

BS-C1B- cell A5

BS-C1B- cell A9A

BS-C1B- cell A9B

BS-C1B- cell B9B

BS-C1B- cell C9B

BS-C1B- cell A19

BS-C1B- cell B19

BS-C1D – General

BS-C1D – Purpose It is said that this template aims at giving an overview of currency mismatches between assets and liabilities and of potential currency risks. If the undertaking has hedged currency risks with derivatives this template does not give a right picture. There should e.g. a row telling the amount of assets / liabilities that is hedged with derivatives / nominal value of derivatives. What are supervisors getting out of this? This is not based on level 2. What is thought to be benefit of this?

BS-C1D – Benefits

BS-C1D – Costs

BS-C1D – Groups

BS-C1D – Materiality

BS-C1D - Disclosure

BS-C1D – Frequency

BS-C1D- cell A1

BS-C1D- cell B1




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BS-C1D- cell C1

BS-C1D- cell D1

BS-C1D- cell E1

BS-C1D- cell A3

BS-C1D- cell A4

BS-C1D- cell A5

BS-C1D- cell A5A

BS-C1D- cell A6

BS-C1D- cell A7

BS-C1D- cell A8

BS-C1D- cell A9

BS-C1D- cell A10

BS-C1D- cell A11

BS-C1D- cell A12

BS-C1D- cell A13

BS-C1D- cell A14

BS-C1D- cell A16

Country - K1– General What should be filled in column FPS? If it is up to underwriting place it will go always to the Home country, if there is no branch. Article 159 of the Framework Directive requires “the amount of premiums, claims and

commissions, without deduction of reinsurance”. Therefore this template should be

restricted to direct business only. (Direct) insurance undertakings might also accept

reinsurance business, but as the template is not applicable for reinsurance

undertakings, the information should exclude accepted reinsurance business.




Deadline

20 January 2012

12:00 CET

Country - K1– Purpose

Country - K1– Benefits

Country - K1– Costs

Country - K1– Groups

Country - K1– Materiality There should also be a threshold related to EEA-jurisdictions. Companies, whose FPS activities are immaterial (mainly serving local companies that have established foreign activities) haven’t built their systems to deliver this kind of detailed information. We think that 25 M€ of premiums is quite small.

Country - K1– Disclosure

Country - K1– Frequency

Country - K1- cell A1




Country - K1- cell C1




Country - K1- cell E1

Is this only commissions (? Or also other expenses – hopefully not because there is not information on other acquisition costs by FPS state in GL, if FPS is not included in home country.

Country - K1- cell E2 See comment in E1.



Country - K1- cell H1 Why Motor Vehicle Liability is taken separately here ?

Country - K1- cell H2

Country - K1- cell H3




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12:00 CET

Country - K1- cell H1A See comment in H1.

Country - K1- cell H2A

Country - K1- cell H3A

Cover - A1A & Q- General As there is only a Balance Sheet in Solvency II, we assume that this information is based on the financial accounts but LoB is as defined for SII purposes. This is an additional burden to compile for undertakings. Is it really needed as we have in the financial statements result by group of EU insurance classes that is quite similar to this? Terminology should be consistent with accounting terminology, if templates are based on financial accounts.

The required allocation of cost differs from the one usually used. We do the bookkeeping based on accrual concept – not cash basis. Therefore our book keeping system does not keep track of expenses paid. High implementation costs are expected because of the required split of expenses paid

(administrative, investment management, claims management etc. expenses ) per SII

LOB. The required breakdown deviates from the current accounting approach. This

template leads to double calculation (SII LOBS and accounting LOBS) based on

different bases (cash and accrual).

Premiums and claims for countries where risk is located could not be found in the GL.

If this is going to be reported it has to be based on internal assumptions. Do such

assumptions fulfil any supervisory purpose?

Reporting the only latest quarter premiums is not consistent with other quarter reportings.




Deadline

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12:00 CET

Localization of risk is difficult to provide. Some (re)insurance contracts may cover several risk locations. In case majority of company’s risks (for example > 95%) are located in home country, the information is not relevant and it should not be required. Why claims paid does not include here salvage and subrogation? In GL they are included in paid claims.

Cover - A1A & Q- Purpose

Cover - A1A & Q- Benefits

Cover - A1A & Q- Costs

Cover - A1A & Q- Groups

Cover - A1A & Q-

Materiality The threshold for data by country is really important for undertakings whose foreign activities are immaterial (mainly serving local companies that has established foreign activities). Could there even be an EUR amount threshold to avoid unmaterial amounts to be required to be reported?

Cover - A1A & Q-

Disclosure

We support EIOPA’s move towards developing a simplified template for public

disclosure however the definitions used must be consistent with IFRS.

Cover - A1A & Q-

Frequency

Cover - A1A- cell A1













Deadline

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Cover - A1A- cell B1

Cover - A1A- cell B2

Cover - A1A- cell C1

Cover - A1A- cell A1A

Cover - A1A- cell B1A

Cover - A1A- cell C1A

Cover - A1A- cell E1

Cover - A1A- cell F1

Cover - A1A- cell G1

Cover - A1A- cell E1A

Cover - A1A- cell F1A

Cover - A1A- cell G1A

The allocation of expenses for reinsurance doesn't reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company's.

Cover - A1A- cell E1B

Comment is only for non-life insurance: The required split into gross-direct business,

gross reinsurance accepted and reinsurers share is not carried out by many insurers.

We propose to report the investment management expense in total instead.

Cover - A1A- cell F1B See comment in E1B

Cover - A1A- cell G1B Comment is only for non-life insurance : The allocation of expenses for reinsurance doesn't reflect




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the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company's. See comment in E1B.

Cover - A1A- cell E1C

Cover - A1A- cell F1C

Cover - A1A- cell G1C

Comment is only for non-life insurance : The allocation of expenses for reinsurance doesn't reflect the nature of non-proportional lines and therefore the results may be artificial and insconsistent between company's.

Cover - A1A- cell E1D

Cover - A1A- cell F1D

Cover - A1A- cell G1D


Cover - A1A- cell E1E

Cover - A1A- cell F1E

Cover - A1A- cell G1E


Cover - A1A- cell I1



Cover - A1A- cell I3A

Cover - A1A- cell I3B








Deadline

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Cover - A1A- cell J1 The non-proportional reinsurance can not be allocated. The line should be removed.

Cover - A1A- cell I11A

Cell I1A : The premium written is not clearly specified. There's on row for it but 2 specifications: Earned premiums in any 12 months and Earned premiums. the first is for risk exposure and part of written premium and the latter due to received in the period and for also to all expenses and commissions but excluding the cherges. We don't know what is wanted. The quarter report needs 3 months?

Cover - A1A- cell J1A

Cover - A1A- cell L1

Cover - A1A- cell M1

Cover - A1A- cell L1A

Cover - A1A- cell M1A

Cover - A1A- cell O1

Cover - A1A- cell P1

Cover - A1A- cell O1A

Cover - A1A- cell P1A

Cover - A1A- cell O1B

Cover - A1A- cell P1B

Cover - A1A- cell O1C

Cover - A1A- cell P1C

Cover - A1Q- cell A1







Deadline

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Cover - A1Q- cell B1

Cover - A1Q- cell B2

Cover - A1Q- cell C1

Cover - A1Q- cell E1

Cover - A1Q- cell F1

Cover - A1Q- cell G1

Cover - A1Q- cell E1Z

Cover - A1Q- cell F1Z

Cover - A1Q- cell G1Z

Cover - A1Q- cell I1



Cover - A1Q- cell I3A




Deadline

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Cover - A1Q- cell I3B









Cover - A1Q- cell L1

Cover - A1Q- cell M1

Cover - A1Q- cell L1Z

Cover - A1Q- cell M1Z

OF - B1A & B1Q – General

OF - B1A & B1Q – Purpose

OF - B1A & B1Q – Benefits

OF - B1A & B1Q – Costs

OF - B1A & B1Q – Groups

OF - B1A & B1Q – Materiality

OF - B1A & B1Q - Disclosure

OF - B1A & B1Q – Frequency

OF - B1A- cell C1A

OF - B1A- cell B5

OF - B1A- cell C5

OF - B1A- cell D5




Deadline

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OF - B1A- cell B6

OF - B1A- cell B10

OF - B1A- cell C10

OF - B1A- cell D10

OF - B1A- cell B11

OF - B1A- cell C11

OF - B1A- cell B14

OF - B1A- cell C14

OF - B1A- cell B17

OF - B1A- cell C17

OF - B1A- cell D17

OF - B1A- cell B18

OF - B1A- cell C18

OF - B1A- cell D18

OF - B1A- cell D14

OF - B1A- cell D11

OF - B1A- cell D15

OF - B1A- cell B25

OF - B1A- cell B30

This information should not be disclosed publicly, because the EPIFP is of no additional

benefit for the public and is sensitive competitive information.

EPIFP is calculated by not allowing offsets between HRG's. HRG is not and cannot not be publicy disclosed segmentation; there may be thousands of HRG according to L2 Articles 28(2) amd 29. The undertaking cannot publish figures whose basis is not public. Another alternative is to calculate EPIFP by not allowing offsets between HRG's but only LoB's.

OF - B1A- cell B31

OF - B1A- cell C33




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OF - B1A- cell C34

OF - B1A- cell C35

OF - B1A- cell D35

OF - B1A- cell C36

OF - B1A- cell D36

OF - B1A- cell C37

OF - B1A- cell C38

OF - B1A- cell D38

OF - B1A- cell C39

OF - B1A- cell C40

OF - B1A- cell D40

OF - B1A- cell C41

OF - B1A- cell D41

OF - B1A- cell C42

OF - B1A- cell D42

OF - B1A- cell A45

OF - B1A- cell A45A

OF - B1A- cell A45B

OF - B1A- cell B60

OF - B1A- cell C60

OF - B1A- cell B61

OF - B1A- cell C61

OF - B1A- cell B62

OF - B1A- cell C62

OF - B1A- cell B64

OF - B1A- cell C64




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OF - B1A- cell B65

OF - B1A- cell C65

OF - B1A- cell B70

OF - B1A- cell C70

OF - B1A- cell B71

OF - B1A- cell C71

OF - B1A- cell B73

OF - B1A- cell C73

OF - B1A- cell D73

OF - B1A- cell E73

OF - B1A- cell F73

OF - B1A- cell B74

OF - B1A- cell C74

OF - B1A- cell D74

OF - B1A- cell E74

OF - B1A- cell F74

OF - B1A- cell B75

OF - B1A- cell C75

OF - B1A- cell D75

OF - B1A- cell E75

OF - B1A- cell F75

OF - B1A- cell A77.1

OF - B1A- cell B77.1

OF - B1A- cell C77.1

OF - B1A- cell D77.1

OF - B1A- cell E77.1




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OF - B1A- cell F77.1

OF - B1A- cell G77.1

OF - B1A- cell H77.1

OF - B1A- cell I77.1

OF - B1A- cell J77.1

OF - B1A- cell K77.1

OF - B1A- cell L77.1

OF - B1A- cell M77.1

OF - B1A- cell N77.1

OF - B1A- cell A77.n

OF - B1A- cell B77.n

OF - B1A- cell C77.n

OF - B1A- cell D77.n

OF - B1A- cell E77.n

OF - B1A- cell F77.n

OF - B1A- cell G77.n

OF - B1A- cell H77.n

OF - B1A- cell I77.n

OF - B1A- cell J77.n

OF - B1A- cell K77.n

OF - B1A- cell L77.n

OF - B1A- cell M77.n

OF - B1A- cell N77.n

OF - B1A- cell B79

OF - B1A- cell C79

OF - B1A- cell D79




Deadline

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OF - B1A- cell E79

OF - B1A- cell F79

OF - B1A- cell B80

OF - B1A- cell C80

OF - B1A- cell D80

OF - B1A- cell E80

OF - B1A- cell F80

OF - B1A- cell B81

OF - B1A- cell C81

OF - B1A- cell D81

OF - B1A- cell E81

OF - B1A- cell F81

OF - B1A- cell B83

OF - B1A- cell C83

OF - B1A- cell D83

OF - B1A- cell B84

OF - B1A- cell C84

OF - B1A- cell D84

OF - B1A- cell B85

OF - B1A- cell C85

OF - B1A- cell D85









Deadline

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OF - B1A- cell B88

OF - B1A- cell C88

OF - B1A- cell B89




Deadline

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OF - B1A- cell B90

OF - B1A- cell C90

OF - B1A- cell B92

OF - B1A- cell C92

OF - B1A- cell D92

OF - B1A- cell E92

OF - B1A- cell F92

OF - B1A- cell B93

OF - B1A- cell C93

OF - B1A- cell D93

OF - B1A- cell E93

OF - B1A- cell F93

OF - B1A- cell B94

OF - B1A- cell C94

OF - B1A- cell D94

OF - B1A- cell E94

OF - B1A- cell F94

OF - B1A- cell B96

OF - B1A- cell C96

OF - B1A- cell D96

OF - B1A- cell E96

OF - B1A- cell B97

OF - B1A- cell C97

OF - B1A- cell D97

OF - B1A- cell E97




Deadline

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OF - B1A- cell B98

OF - B1A- cell C98

OF - B1A- cell D98

OF - B1A- cell E98








If the lenders of a subordinated loans are specified in E100.1-n what are the counterparties to be specified in G100.1-n?







We question whether « Notice » is the last point in time when the borrower of a subordinated loan is supposed to notify the lenders that it wants to pay back the loan on a call date?












Deadline

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OF - B1A- cell B102

OF - B1A- cell C102

OF - B1A- cell D102

OF - B1A- cell B103

OF - B1A- cell C103

OF - B1A- cell D103

OF - B1A- cell B104

OF - B1A- cell C104

OF - B1A- cell D104














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OF - B1A- cell A108

OF - B1A- cell B108

OF - B1A- cell C108

OF - B1A- cell B109

OF - B1A- cell D109

OF - B1A- cell B110

OF - B1A- cell C110

OF - B1A- cell D110




Deadline

20 January 2012

12:00 CET

OF - B1A- cell E110

OF - B1A- cell B111

OF - B1A- cell C111

OF - B1A- cell D111

OF - B1A- cell E111



















OF - B1A- cell B116

OF - B1A- cell D116

OF - B1A- cell E116




Deadline

20 January 2012

12:00 CET

OF - B1A- cell F116





























Deadline

20 January 2012

12:00 CET


OF - B1Q- cell C1A

OF - B1Q- cell B5

OF - B1Q- cell C5

OF - B1Q- cell D5

OF - B1Q- cell B6

OF - B1Q- cell B10

OF - B1Q- cell C10

OF - B1Q- cell D10

OF - B1Q- cell B11

OF - B1Q- cell C11

OF - B1Q- cell B14

OF - B1Q- cell C14

OF - B1Q- cell B17

OF - B1Q- cell C17

OF - B1Q- cell D17

OF - B1Q- cell B18

OF - B1Q- cell C18

OF - B1Q- cell D18

OF - B1Q- cell D14

OF - B1Q- cell D11

OF - B1Q- cell D15

OF - B1Q- cell B25

OF - B1Q- cell B30

OF - B1Q- cell B31

OF - B1Q- cell C33




Deadline

20 January 2012

12:00 CET

OF - B1Q- cell C34

OF - B1Q- cell C35

OF - B1Q- cell D35

OF - B1Q- cell C36

OF - B1Q- cell D36

OF - B1Q- cell C37

OF - B1Q- cell C38

OF - B1Q- cell D38

OF - B1Q- cell C39

OF - B1Q- cell C40

OF - B1Q- cell D40

OF - B1Q- cell C41

OF - B1Q- cell D41

OF - B1Q- cell C42

OF - B1Q- cell D42

OF - B1Q- cell A45

OF - B1Q- cell A45A

OF - B1Q- cell A45B

VA - C2A– General We propose to delay this template. It is because every company should create themselves their own internal reporting systems, and that should be enough also to the supervisors. This kind of templates also need testing with real numbers. There seems to be mismatch between VA-templates and others. These templates require re-calculations when parameters change. Reporting of these should be removed to the future when companies have more experience of Solvency II and they have had time to build their internal reporting systems. Applying to groups is very burdensome (time, resources, IT-system,etc.)




Deadline

20 January 2012

12:00 CET

The templates are still based on underwriting year, which is not available in existing reporting systems that are based on the accident year. For a non-life company there is no difference in risk whether insurance is underwritten in current or prior year. This is not a major risk driver why this split is unnecessary. The Analysis templates regarding cash flows are difficult to understand. What is information on cash-flows during the reporting period? We do not understand the rows? Difficult to say if it is possible or impossible to report them. (There's no place to comment V1…22) It seems that the references for cells have been made for some old version of OF – B1A V2 should refer to OF – B1A cell A69 and A72, not D65 and A65. V3 should refer to OF – B1A cell D66 and A66, not D71/75 and A71/75. V5 line 163 must be replace by 146. V6 line 200 must be replace by 189+190. V7 should refer to OF – B1A cell D95 and A99, not F83 and A83. Please, check the rest of cells …

VA – C2A – Purpose We see the purpose of specifying changes in OF that are due to SII adjustments – but most of the changes between balance b/fwd and balance c/fwd are related to changes that is shown in the legal P&L account and should not be reported here.

VA – C2A – Benefits It is difficult to see any benefits in double reporting, where additional reporting is just for the supervision, not used by the industry itself. Most likely the industry uses the statutory P&L to describe changes in equity.

VA – C2A - Costs All reporting is currently done based on accident year. Developing reporting based on UW-year will mean extremly high cost. To maintain and run double reporting systems will also mean high additional costs.

VA – C2A – Groups

VA - C2A – Materiality

VA - C2A – Disclosure




Deadline

20 January 2012

12:00 CET

VA – C2A – Frequency

VA - C2B– General Applying to groups is very burdensome (time, resources, IT-system,etc.) Further clarification required: - How different types of derivatives should be handled on this template. Should the values in the cell 01 and 05 Opening and Closing investments Balance sheet be dirty values or clean values? Please see the CEA`s comments in the ASSET – D1 – Cell A26 Total S II amount. Guidance on filling templates is in too general level, it will lead to non-harmonised outcome. It does not have any meaning for business when something is purchased, only result has the meaning. This is not reasonable for company’s real investment business. It will require big changes for systems, and it won’t match with companies’ follow up of investments. What is the purpose of reporting of these changes in key figures? This approach will imply a big investment. We will need an additional general ledger – Solvency II ledger – to fulfil this reporting. This additional ledger requires a cash-based accounting, a total different approach from today’s accounting principles within the company. How should the reporting be done when company uses an average balance principle? Having investments in several currencies make it more complicated and more expensive to implement.

VA – C2B – Purpose This report will not fulfil the purpose. 1) Revenues (interests) in ordinary P&L are not cash flow based, 2) expenses related to investments are not cash flow based.

VA – C2B – Benefits

VA – C2B - Costs




Deadline

20 January 2012

12:00 CET

VA – C2B – Groups

VA - C2B – Materiality

VA - C2B – Disclosure

VA – C2B – Frequency

VA C2B - cell AA2 There are also negative cash flows from derivatives, should those be in this cell or should all derivatives be handled net in cell A1 or A4. See general comments.

VA C2B -cell A1

Does this include all the returns from derivatives? In the LOG document stands: ”Also aplicable to derivatives generating cash flows”. Please compare to Asset D3- A7: "Also applicable to derivatives generating interest flows" See general comments.

VA C2B -cell A2 Should dividents be gross or net?

VA C2B -cell A3

VA C2B -cell A4 Should other derivatives than interest generating detivatives be reported here? See A1.

VA C2B -cell A6

It is difficult to separate changes in valuation of assets between held at opening balance sheet and acquired during the period. Especially in situations where we have some instrument in the portfolio already in the beginning of year and then we buy more and sell some after that and buy more etc. . In portfolio where average price principle is used it is not possible to report the changes separately. What is the meaning with this separation or could cells A6 and A8 be only one line? (if this is the only way to do it) We do not see this kind of split useful for internal purposes. The best solution would be to classify these by property classes. This applies to A6-A8 if VA can’t be postponed.

VA C2B -cell A7

Unclear about what should be reported here. Should capital reductions and redemptions be reported here and also the variation margin of derivatives which are received or paid on a daily basis although they are not sold or closed.




Deadline

20 January 2012

12:00 CET

VA C2B -cell A8 See A6

VA C2B -cell O1

VA C2B -cell O2

VA C2B -cell O3 Should the capital reductions and redemptions be handled here as sale like in cell A7?

VA - C2C– General Applying to groups is very burdensome (time, resources, IT-system,etc.) Separate templetes for direct and reinsurance businesses. It is difficult to report the reinsurance to new and old business. The reinsurance template should be simpler. We are not and will not be able to report premiums, claims and expenses divided into UW year. It doesn’t add any value to divide premiums and claims to the year then the risk was accepted. For non-life undertakings new business does not have higher risk than old business. The template is constructed for life undertakings. It is difficult to separate claims, expenses and technical provisions between risks

accepted during the period and risks accepted prior to the period. When we do

calculations we use accident year and not underwriting year.

Calculation of Technical Provisions provide a choice of either accident year or

underwriting year basis. The QRT should be consistent to this.

The combination of risk accepted and LoB for expenses will have to be based on assumptions that can not be checked and reconciled. What value would such reporting give for supervisory purposes? It would be good if EIOPA could prepare a formula document to show into what parts the variance TPN-TPN-1 is analyzed because there are several ways to analyse it. The text in General is not detailed enough. From the document it would be easier to conclude what the calculations




Deadline

20 January 2012

12:00 CET

assumed really are. Now their specifications are quite obscure. Eg.

Take account of the effect of unwinding discount rate (see cell A2)

- Based on this adjusted figure (BE at closing N-1 + A2) , run the calculation

with the change of discount rates that applied during year N

or

Step d/ based on figure (c) i.e., after the unwinding of discount rate and after

changes in discount rates, simulate the changes in assumptions that applied

during year N (if any) this will provide the variation of BE related to

changes in assumptions (cell BB5=A3(economic assumptions) + B3 (non

economic assumptions)

Step e/ consider total BE at the closing of year end N (source BS-C1 and =

cell BB8 in VA C2C) and derive the variation of BE due to experience on

risks accepted prior to period (cell BB6=E4) as follows: … don't give guideline how really to calculate. What is the adjusted figure of BE and what is the policy data? The most usual variance analysis for the risks accepted prior to period is

TPN-TPN-1 = [TPN- TPN(old estimates and assumptions)] + [TPN(old estimates and assumptions)- TPN(expected at N-1)] + [TPN(expected at N-1)- TPN-1] =

= [TPN- TPN(old estimates and assumptions)] + [TPN(old estimates and assumptions)- TPN(expected

at N-1)]+ [unwinding + netCFN(expected at N-1)] =

= changes due to estimate and assumption changes calculated at N with the actual portfolio + changes due to variance in year N calculated at N with old assumptions and estimates and the

actual portfolio +




Deadline

20 January 2012

12:00 CET

netCFN(actual)+ unwinding Here netCF the cash flows during year N. TPN(expected at N-1) is easily calculated from the expected cash flows from which the cash flows of year N is excluded. Those cash flows have been calculated a year before. The separation to estimate and assumption changes doesn't seem to be generally accepted. Should the separation to be financial and other non-operational and operational changes? See for more arguments the comments to cell BB1. If there is non-proportional reinsurance the recovarables are burdensome to allocate for the risks accepted during and prior period. It would be better to treat ceded insurance and reinsurance separately? There should be Article reference (to L1 and L2) whose requirements the template satisfies. Risks accepted: In P&C business the claim liability is allocated according to accident year and the re-allocation to the year accepted is not preferable. In other reports the claim liability is reported acording to the accident year and it would be preferable that the reporting occurs every in the same way. It is relevant when the event has occured not when it has been accepted. The main question if the reserving is correct. In the life business more relevant is the correcteness of the future premiums. In life business this easier but there are problems if the allocation requires that the contracts where there has been additional selling should be calculated in two times, before the additional selling (which is unneeded elsewhere and makes the calculation too complex) and after. The solution shall be to report only totally new risks accepted. Distinction between “risk accepted during / prior to reporting period” i.e. underwriting year (UWY) is difficult to produce and the information is not currently available for claims in several lines of business. Thus, approximations should be used. However, accident year (AY) based information




Deadline

20 January 2012

12:00 CET exists, as the technical provisions are calculated as the AY basis. It should be allowed to use AY in stead of UWY. Clarification of signs of figures should be made. For example Claims and benefits seems to have “+” sign and BE cash flows “-“-sign. This is somewhat contradictory.

VA – C2C – Purpose The LOG should be changed to clarify EIOPA’s intention with this template i.e.

it should read “change in best estimate of cashflow” and not “best estimate of cashflow”. See the previous comment.

VA – C2C – Benefits

VA – C2C - Costs Expenses paid is not available in accounting now and hence system chances are

needed. Premiums paid is not available from the systems now, only premiums written. Changes in systems will cause costs.

VA – C2C – Groups

VA - C2C – Materiality

VA - C2C – Disclosure

VA – C2C – Frequency

VA C2C -cell AA5

VA C2C -cell A1

VA C2C -cell B1

VA C2C -cell C1 Salvage and subrogation can not be separated. Include this in claims and benefits paid instead.

VA C2C -cell D1

VA C2C -cell E1 Sign “-“ should be clarified, or if the sign is “+” then formula in F1 is wrong?!

VA C2C -cell E1A Sign “-“ should be clarified, or if the sign is “+” then formula in F1 is wrong?!

VA C2C -cell G1 Should be change in reinsurance and SPV recoverables as the actual payments could but doesn’t have to effect own funds.




Deadline

20 January 2012

12:00 CET

In the case of the non-proportional reinsurance the recovarables are burdensome to allocate for the risks accepted during period.

VA C2C -cell H1 In the case of the non-proportional reinsurance the recovarables are burdensome to allocate for the risks accepted during period.

VA C2C -cell E1A

VA C2C -cell A2 What does mean discount rates that applied during year N? It changes all the time.

What is calculation of the unwinding of discount rates ? Is it run of one year N? Isn't the approximation TP at the year end * yield of 1 y at the year end of N-1 sufficient? It is used regurarly in the embedded value calculations.

VA C2C -cell B2

VA C2C -cell D2 Based on this adjusted figure (BE at closing N-1 + A2) , run the calculation with the

change of discount rates that applied during year N this will provide the variation of

BE strictly related to changes of discount rate is not a clear guideline. What does mean run the calculation.

What is adjusted figure (BE at closing N-1 + A2)? Portfolio at year end N-1 where BE is the old BE + A2 or what? This seems to be applied to the old expected portfolio and therefore the effect of change is made to the situation where the current discount rate didn't exist. Because the experience analysis should first performed this change of estimate should be performed by using the portfolio at year end N excluding the new business using the discount rate at year end N-1 and N (which is the BE). See comment in General.

VA C2C -cell E2 See the previous comment.

VA C2C -cell G2 See the previous comment.

VA C2C -cell A3 In order to isolate this strict scope of variation, the calculation should be the following:

- Consider total BE at the closing of the period N-1 (i.e., based on former assumptions…) –

this figure should be equal to that in TP E1/F1 at year end N-1.

- Based on this figure, preliminary take account of the effect of unwinding discount rate

and changes in discount rate (see cells A2 and D2)




Deadline

20 January 2012

12:00 CET

- then, based on this adjusted figure, run calculations of the changes in economic

assumptions that applied during year N (if any) this will provide the variation of BE

strictly related to changes in economic assumptions is not a clear guideline. What does mean run the calculation. Portfolio? This calculation should be done using the actual portfolio at year end N using the current discount and first old economic assumptions and secondly new ones.

VA C2C -cell B3 See the previous comment.

VA C2C -cell C3 See the previous comment.

VA C2C -cell A4

VA C2C -cell B4

VA C2C -cell C4 Salvage and subrogation can not be separated. Include this in claims and benefits paid instead.

VA C2C -cell D4 Expenses paid is not available in accounting now and hence system chances are

needed.

VA C2C -cell E4

VA C2C -cell E4A

VA C2C -cell G4 Please refer to VA – C2C – cell G1 for comments on reinsurance recoverables.

VA C2C -cell H4

VA C2C -cell BB1 See the comments in General. This is not very clear guideline. The order of the calculation doesn't seem to be correct or optimal. If the experience variance is calculated after the changes of the assumptions and estimates then the changes of the assumptions and estimates are based on the portfolio at year end N-1 even though those changes hadn't been done then but at year end N. It is not consistent. It would be




Deadline

20 January 2012

12:00 CET

be difficult to construct the portfolio at the end year N which would have been expected at year end N-1 but the cash flows from year N on exist and they need no adjustment. Therefore, the opposite calculation order in the comments in General is recommended. Steps c and d and therefore partly e don't identify which portfolio is used. The opposite order is followed mainly by the embedded value calculations. In IFRS 4 Phase II it has not been decided yet how the variance analysis is done but the discussion go to that opposite direction. In order that the companies can use the same clear and good practice and definitions everywhere in their reporting we support the opposite order. Please, see for the discussion in IFRS 4 Phase II the staff papers 4D p.29 in http://www.ifrs.org/Meetings/IASB+FASB+Meeting+October+2011.htm and paper 3A p.2-3 in http://www.ifrs.org/Meetings/IASB+Meeting+June+2011.htm. where the order is (i) building block approach underwriting margin (being the experience variance) (ii) experience adjustment related to the current period (iii)changes in assumptions For the embedded value calculation, please, see Annex A on p. 27 in http://www.cfoforum.nl/downloads/MCEV_Principles_and_Guidance_October_2009.pdf where the order of the relevant items is Opening MCEV New business value Expected existing business contribution (referencerate) (1) (2) This is experience variance Expected existing business contribution (in excess of reference rate) (1) (3) This is experience variance

Experience variances Assumption changes Economic variances Closing MCEV The guideline p.35 paragraph 179 states that the above order is the one which is recommended

http://www.ifrs.org/Meetings/IASB+FASB+Meeting+October+2011.htm

http://www.ifrs.org/Meetings/IASB+Meeting+June+2011.htm

http://www.cfoforum.nl/downloads/MCEV_Principles_and_Guidance_October_2009.pdf




Deadline

20 January 2012

12:00 CET

even though exceptions are allowed. http://www.cfoforum.nl/downloads/CFO_Forum_MCEV_Basis_for_Conclusions.pdf The definition shall be replaced by Steps a and b as expressed. Step c /the cash flows during year N Step d/ Calculate from the cash flows generated the year before with the assumptions then the TP at N. Step e/ Calculate with the actual policy data at N with the assumptions the year earlier (as in d) the TP at N. Step f/ Calculate with the actual policy data at N with the actual assumptions the TP at N.

VA C2C -cell CC1

VA - C2D– General

VA – C2D – Purpose

VA – C2D – Benefits

VA – C2D - Costs

VA – C2D – Groups

VA - C2D – Materiality

VA - C2D – Disclosure

VA – C2D – Frequency

VA C2D -cell O2

VA C2D -cell O3

VA C2D -cell O4

VA C2D -cell O6

VA C2D -cell O7

VA C2D -cell O8

VA C2D -cell O9

http://www.cfoforum.nl/downloads/CFO_Forum_MCEV_Basis_for_Conclusions.pdf




Deadline

20 January 2012

12:00 CET

VA C2D -cell O10

VA C2D -cell O11

VA C2D -cell O12

SCR - B2A – General Should the title be only for Standard Formula?

SCR - B2A – Purpose

SCR - B2A – Benefits

SCR - B2A – Costs

SCR - B2A – Groups

SCR - B2A – Materiality

SCR - B2A - Disclosure

SCR - B2A – Frequency

SCR - B2A - cell A1

This is a general comment on the colouring chart provided in the templates. The chart suggests that cyan fields are calculated with a formula, and green fields are calculated as total sum. Is this a calculation functionality provided by EIOPA similarly to QIS5, or something else? There are inconsistencies within what is now marked as calculated, compare e.g. SCR-B3C where diversification effect and total capital requirement are shown as calculated, and SCR-B3D where similar fields are not shown as calculated.

SCR - B2A - cell B1

SCR - B2A - cell A2

SCR - B2A - cell B2

SCR - B2A - cell A3

SCR - B2A - cell B3

SCR - B2A - cell A4

SCR - B2A - cell B4




Deadline

20 January 2012

12:00 CET

SCR - B2A - cell A5

SCR - B2A - cell B5=A5

SCR - B2A - cell A6

In a setup where undertaking is using PIM to calculate capital requirement for e.g. parts of market risks, is the diversification between SF modules still relevant? Or should the total diversification stemming from PIM and SF calculated parts be shown on A9, where the aggregation rules leading to diversification effect between SF calculated parts and PIM parts has been agreed with the supervisor.

SCR - B2A - cell B6


SCR - B2A - cell A7

SCR - B2A - cell B7=A7

SCR - B2A - cell A8

SCR - B2A - cell B8


SCR - B2A - cell A9


SCR - B2A - cell B9

SCR - B2A - cell A11

The log and the template both have different formulae, both inconsistent with the L2 (Oct 2011) text. Shouldn’t it be –max (min(B10-A10;FDB);0)?





Deadline

20 January 2012

12:00 CET



SCR - B2A - cell A14A

SCR - B2A - cell A15A

SCR - B2A - cell A15B

SCR - B2A - cell A15C







SCR - B2B – General

SCR - B2B – Purpose

SCR - B2B – Benefits

SCR - B2B – Costs

SCR - B2B – Groups

SCR - B2B – Materiality

SCR - B2B - Disclosure

SCR - B2B – Frequency

SCR - B2B- cell A1.1

SCR - B2B- cell A1A.1

SCR - B2B- cell B1.1

SCR - B2B- cell A1.n

SCR - B2B- cell A1A.n




Deadline

20 January 2012

12:00 CET

SCR - B2B- cell B1.n

SCR - B2B- cell B3

SCR - B2B- cell B5

SCR - B2B- cell B6

SCR - B2B- cell B8

SCR - B2C – General

SCR - B2C – Purpose

SCR - B2C – Benefits

SCR - B2C – Costs

SCR - B2C – Groups

SCR - B2C – Materiality

SCR - B2C- Disclosure

SCR - B2C – Frequency

SCR - B2C- cell A1.1

SCR - B2C- cell A1A.1

SCR - B2C- cell B1.1

SCR - B2C- cell A1.n

SCR - B2C- cell A1A.n

SCR - B2C- cell B1.n

SCR - B2C- cell B3

SCR - B2C- cell B5

SCR - B2C- cell B6

SCR - B2C- cell B7

SCR - B2C- cell B7A

SCR - B2C- cell B8A




Deadline

20 January 2012

12:00 CET

SCR - B2C- cell B8B

SCR - B2C- cell B8C

SCR - B2C- cell B9

SCR - B2C- cell B10

SCR - B2C- cell B11

SCR - B2C- cell B13

SCR - B2C- cell B14

SCR - B2C- cell B15

SCR - B3A – General

SCR - B3A – Purpose

SCR - B3A – Benefits

SCR - B3A – Costs

SCR - B3A – Groups

SCR - B3A – Materiality

SCR - B3A - Disclosure

SCR - B3A – Frequency

SCR - B3A- cell CO

SCR - B3A- cell D0

SCR - B3A- cell A1

SCR - B3A- cell A1A

SCR - B3A- cell B1

SCR - B3A- cell B1A

SCR - B3A- cell C1

SCR - B3A- cell B1B

SCR - B3A- cell D1




Deadline

20 January 2012

12:00 CET

SCR - B3A- cell A2 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell A2A

SCR - B3A- cell B2 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell B2A If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell C2 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell B2B If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell D2 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell C3

In the definition the correlation is missing. Should be 2

221

2

1 75.02 equitiestypeequitiestypeequitiestypeequitiestypeequity SCRSCRSCRSCRSCR

SCR - B3A- cell D3

In the definition the correlation is missing. Should be 2

221

2

1 75.02 equitiestypeequitiestypeequitiestypeequitiestypeequity SCRSCRSCRSCRSCR

SCR - B3A- cell A4

SCR - B3A- cell A4A

SCR - B3A- cell B4

SCR - B3A- cell B4A

SCR - B3A- cell C4

SCR - B3A- cell B4B

SCR - B3A- cell D4

SCR - B3A- cell A5

SCR - B3A- cell B5

SCR - B3A- cell A6

SCR - B3A- cell B6

SCR - B3A- cell A7

SCR - B3A- cell B7

SCR - B3A- cell A8




Deadline

20 January 2012

12:00 CET

SCR - B3A- cell A8A

SCR - B3A- cell B8

SCR - B3A- cell B8A

SCR - B3A- cell B8B

SCR - B3A- cell D8

SCR - B3A- cell A9

SCR - B3A- cell B9

SCR - B3A- cell A10

SCR - B3A- cell B10

SCR - B3A- cell A11

SCR - B3A- cell B11

SCR - B3A- cell A12

SCR - B3A- cell A12A

SCR - B3A- cell B12

SCR - B3A- cell B12A

SCR - B3A- cell C12

SCR - B3A- cell B12B

SCR - B3A- cell D12

SCR - B3A- cell C13

SCR - B3A- cell D13

SCR - B3A- cell A14


SCR - B3A- cell B14


SCR - B3A- cell C14





Deadline

20 January 2012

12:00 CET

SCR - B3A- cell D14

SCR - B3A- cell C15

SCR - B3A- cell D15

SCR - B3A- cell A16


SCR - B3A- cell B16


SCR - B3A- cell C16


SCR - B3A- cell D16

SCR - B3A- cell A17 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell A17A If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell B17 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell B17A If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell C17 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell B17B If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell D17 If this is known to have smaller NAV change it should be possible to leave this uncompleted.

SCR - B3A- cell A18


SCR - B3A- cell B18


SCR - B3A- cell C18


SCR - B3A- cell D18

SCR - B3A- cell A19





Deadline

20 January 2012

12:00 CET

SCR - B3A- cell C19

SCR - B3A- cell D19

SCR - B3A- cell A20


SCR - B3A- cell C20

SCR - B3A- cell D20

SCR - B3A- cell A21


SCR - B3A- cell B21


SCR - B3A- cell C21


SCR - B3A- cell D21

SCR - B3A- cell C22

SCR - B3A- cell D22

SCR - B3A- cell C23

SCR - B3A- cell D23

SCR - B3B – General

SCR - B3B – Purpose

SCR - B3B – Benefits

SCR - B3B – Costs

SCR - B3B – Groups

SCR - B3B – Materiality

SCR - B3B - Disclosure

SCR - B3B – Frequency




Deadline

20 January 2012

12:00 CET

SCR - B3B- cell A0

SCR - B3B- cell B0

SCR - B3B- cell A1

SCR - B3B- cell A1A

SCR - B3B- cell A2

SCR - B3B- cell A3

SCR - B3B- cell A4

SCR - B3B- cell B6

SCR - B3B- cell A7

SCR - B3B- cell A8

SCR - B3B- cell A9

SCR - B3B- cell B9

SCR - B3C – General

SCR - B3C – Purpose

SCR - B3C – Benefits

SCR - B3C – Costs

SCR - B3C – Groups

SCR - B3C – Materiality

SCR - B3C - Disclosure

SCR - B3C – Frequency

SCR - B3C- cell A1

SCR - B3C- cell A1A

SCR - B3C- cell B1

SCR - B3C- cell B1A

SCR - B3C- cell C1




Deadline

20 January 2012

12:00 CET

SCR - B3C- cell B1B

SCR - B3C- cell D1

SCR - B3C- cell A2

SCR - B3C- cell A2A

SCR - B3C- cell B2

SCR - B3C- cell B2A

SCR - B3C- cell C2

SCR - B3C- cell B2B

SCR - B3C- cell D2

SCR - B3C- cell A3

SCR - B3C- cell A3A

SCR - B3C- cell B3

SCR - B3C- cell B3A

SCR - B3C- cell C3

SCR - B3C- cell B3B

SCR - B3C- cell D3

SCR - B3C- cell C04

If it is evident which scenario gives the highest stress it should be possible to leave the other two scenarios uncompleted.

SCR - B3C- cell D04

If it is evident which scenario gives the highest stress it should be possible to leave the other two scenarios uncompleted.

SCR - B3C- cell A4

SCR - B3C- cell A4A

SCR - B3C- cell B4

SCR - B3C- cell B4A

SCR - B3C- cell C4

SCR - B3C- cell B4B

SCR - B3C- cell D4




Deadline

20 January 2012

12:00 CET

SCR - B3C- cell A5

SCR - B3C- cell A5A

SCR - B3C- cell B5

SCR - B3C- cell B5A

SCR - B3C- cell C5

SCR - B3C- cell B5B

SCR - B3C- cell D5

SCR - B3C- cell A6

SCR - B3C- cell A6A

SCR - B3C- cell B6

SCR - B3C- cell B6A

SCR - B3C- cell C6

SCR - B3C- cell B6B

SCR - B3C- cell D6

SCR - B3C- cell A7

SCR - B3C- cell A7A

SCR - B3C- cell B7

SCR - B3C- cell B7A

SCR - B3C- cell C7 In the guidelines there is the printing error telling this cell is C77

SCR - B3C- cell B7B

SCR - B3C- cell D7

SCR - B3C- cell A8

SCR - B3C- cell A8A

SCR - B3C- cell B8

SCR - B3C- cell B8A

SCR - B3C- cell C8




Deadline

20 January 2012

12:00 CET

SCR - B3C- cell B8B

SCR - B3C- cell D8

SCR - B3C- cell A9

SCR - B3C- cell A9A

SCR - B3C- cell B9

SCR - B3C- cell B9A

SCR - B3C- cell C9

SCR - B3C- cell B9B

SCR - B3C- cell D9

SCR - B3C- cell C10

SCR - B3C- cell D10

SCR - B3C- cell C11

SCR - B3C- cell D11

SCR - B3C- cell A12

The log document states that this needs to be filled only if the factor use is truly undertaking specific, and not if it is the one proposed in the SF. For practical purposes, should one always fill the field, even if the parameter use is equal to the one proposed in the L2 text.

SCR - B3D – General

SCR - B3D – Purpose

SCR - B3D – Benefits

SCR - B3D – Costs

SCR - B3D – Groups

SCR - B3D – Materiality

SCR - B3D - Disclosure

SCR - B3D – Frequency

SCR - B3D- cell A12




Deadline

20 January 2012

12:00 CET

SCR - B3D- cell A12A

SCR - B3D- cell B12

SCR - B3D- cell C12

SCR - B3D- cell D12

SCR - B3D- cell E12

SCR - B3D- cell F12

SCR - B3D- cell A13


SCR - B3D- cell B13

SCR - B3D- cell C13

SCR - B3D- cell D13

SCR - B3D- cell E13

SCR - B3D- cell F13

SCR - B3D- cell A14


SCR - B3D- cell B14

SCR - B3D- cell C14

SCR - B3D- cell D14

SCR - B3D- cell E14

SCR - B3D- cell F14

SCR - B3D- cell A15


SCR - B3D- cell B15

SCR - B3D- cell C15

SCR - B3D- cell D15

SCR - B3D- cell E15




Deadline

20 January 2012

12:00 CET

SCR - B3D- cell F15

SCR - B3D- cell A16

SCR - B3D- cell A17

SCR - B3D- cell A18


SCR - B3D- cell B18

SCR - B3D- cell B18A

SCR - B3D- cell C18

SCR - B3D- cell A19

SCR - B3D- cell A20

SCR - B3D- cell A21

This is calculated also in B3F –why could not be taken from there ?

SCR - B3D- cell A22 See A21

SCR - B3D- cell A23 See A21

SCR - B3D- cell A24

SCR - B3D- cell A25

SCR - B3D- cell A26

SCR - B3D- cell A27

SCR - B3E – General

SCR - B3E – Purpose

SCR - B3E – Benefits

SCR - B3E – Costs

SCR - B3E – Groups

SCR - B3E – Materiality

SCR - B3E - Disclosure




Deadline

20 January 2012

12:00 CET

SCR - B3E – Frequency

SCR - B3E- cell A1


SCR - B3E- cell A1A

SCR - B3E- cell B1


SCR - B3E- cell C1

SCR - B3E- cell D1

SCR - B3E- cell E1

SCR - B3E- cell F1

SCR - B3E- cell A2


SCR - B3E- cell A2A

SCR - B3E- cell B2


SCR - B3E- cell C2

SCR - B3E- cell D2

SCR - B3E- cell E2

SCR - B3E- cell F2

SCR - B3E- cell A3


SCR - B3E- cell A3A

SCR - B3E- cell B3 The log document states that this needs to be filled only if the factor use is truly undertaking




Deadline

20 January 2012

12:00 CET

specific, and not if it is the one proposed in the SF. For practical purposes, should one always fill the field, even if the parameter use is equal to the one proposed in the L2 text.

SCR - B3E- cell C3

SCR - B3E- cell D3

SCR - B3E- cell E3

SCR - B3E- cell F3

SCR - B3E- cell A4


SCR - B3E- cell A4A

SCR - B3E- cell B4


SCR - B3E- cell C4

SCR - B3E- cell D4

SCR - B3E- cell E4

SCR - B3E- cell F4

SCR - B3E- cell A5


SCR - B3E- cell A5A

SCR - B3E- cell B5


SCR - B3E- cell C5

SCR - B3E- cell D5

SCR - B3E- cell E5

SCR - B3E- cell F5




Deadline

20 January 2012

12:00 CET

SCR - B3E- cell A6


SCR - B3E- cell A6A

SCR - B3E- cell B6


SCR - B3E- cell C6

SCR - B3E- cell D6

SCR - B3E- cell E6

SCR - B3E- cell F6

SCR - B3E- cell A7


SCR - B3E- cell A7A

SCR - B3E- cell B7


SCR - B3E- cell C7

SCR - B3E- cell D7

SCR - B3E- cell E7

SCR - B3E- cell F7

SCR - B3E- cell A8


SCR - B3E- cell A8A

SCR - B3E- cell B8





Deadline

20 January 2012

12:00 CET

SCR - B3E- cell C8

SCR - B3E- cell D8

SCR - B3E- cell E8

SCR - B3E- cell F8

SCR - B3E- cell A9


SCR - B3E- cell A9A

SCR - B3E- cell B9


SCR - B3E- cell C9

SCR - B3E- cell D9

SCR - B3E- cell E9

SCR - B3E- cell F9

SCR - B3E- cell A10


SCR - B3E- cell A10A

SCR - B3E- cell B10


SCR - B3E- cell C10

SCR - B3E- cell D10

SCR - B3E- cell E10

SCR - B3E- cell F10

SCR - B3E- cell A11

The log document states that this needs to be filled only if the factor use is truly undertaking specific, and not if it is the one proposed in the SF. For practical purposes, should one always fill




Deadline

20 January 2012

12:00 CET

the field, even if the parameter use is equal to the one proposed in the L2 text.


SCR - B3E- cell B11


SCR - B3E- cell C11

SCR - B3E- cell D11

SCR - B3E- cell E11

SCR - B3E- cell F11

SCR - B3E- cell A12



SCR - B3E- cell B12


SCR - B3E- cell C12

SCR - B3E- cell D12

SCR - B3E- cell E12

SCR - B3E- cell F12

SCR - B3E- cell A13

SCR - B3E- cell A14

SCR - B3E- cell A15


SCR - B3E- cell B15

SCR - B3E- cell B15A

SCR - B3E- cell C15




Deadline

20 January 2012

12:00 CET

SCR - B3E- cell A16 Why this is not taken from B3F ?

SCR - B3E- cell A17

SCR - B3E- cell A18

SCR - B3F – General

SCR - B3F – Purpose

SCR - B3F – Benefits

SCR - B3F – Costs

SCR - B3F – Groups

SCR - B3F – Materiality

SCR - B3F - Disclosure

SCR - B3F – Frequency

SCR - B3F- cell Summary

A1


C1


A9


C9


A17


C17


A26


C26





Deadline

20 January 2012

12:00 CET

A27


C27

SCR - B3F- cell Windstorm

A1

The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country (ies)? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20?


B1


C1


E1


F1


G1


H1


A2 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country (ies)? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20?


B2


C2


E2





Deadline

20 January 2012

12:00 CET

F2


G2


H2




B3


C3


E3


F3


G3


H3




B20


C20





Deadline

20 January 2012

12:00 CET

E20


F20


G20


H20


A22


F22


G22


H22


I22


F25


I25

SCR - B3F- cell Earthquake

A1

The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.


B1


C1


E1




Deadline

20 January 2012

12:00 CET


F1


G1


A2 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.


B2


C2


E2


F2


G2




B3


C3


E3


F3




Deadline

20 January 2012

12:00 CET


G3




B20


C20


E20


F20


G20


A22


E22


F22


G22


H22


E25


H25

SCR - B3F- cell Flood A1 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that




Deadline

20 January 2012

12:00 CET

relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.

SCR - B3F- cell Flood B1

SCR - B3F- cell Flood C1

SCR - B3F- cell Flood E1

SCR - B3F- cell Flood F1

SCR - B3F- cell Flood G1

SCR - B3F- cell Flood H1

SCR - B3F- cell Flood A2 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.













Deadline

20 January 2012

12:00 CET












SCR - B3F- cell Flood A22




SCR - B3F- cell Flood I22


SCR - B3F- cell Flood I25

SCR - B3F- cell Hail A1

The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.

SCR - B3F- cell Hail B1




Deadline

20 January 2012

12:00 CET

SCR - B3F- cell Hail C1

SCR - B3F- cell Hail E1

SCR - B3F- cell Hail F1

SCR - B3F- cell Hail G1

SCR - B3F- cell Hail H1

SCR - B3F- cell Hail A2 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.







SCR - B3F- cell Hail A3 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.







SCR - B3F- cell Hail A20 The row labels refer to EEA regions 1 to 20. Is there supposed to be a relation somewhere that




Deadline

20 January 2012

12:00 CET

relates e.g. EEA region 1 to a specific country(ies) ? L2 (Oct 2011) text specifically excludes some countries in the EEA region from certain natural catastrophes. Is this taken into account somehow in the reporting, since each natural catastrophe seems to be a rolling list from EEA region 1 to EEA region 20.







SCR - B3F- cell Hail A22




SCR - B3F- cell Hail I22


SCR - B3F- cell Hail I25

SCR - B3F- cell Subsidence

A1


B1


C1


F1


G1


H1




Deadline

20 January 2012

12:00 CET


E3


H3

SCR - B3F- cell Non-

proportional property

reinsurance A1



reinsurance B1



reinsurance C1



reinsurance D1

SCR - B3F- cell Motor

Vehicle Liability A1









SCR - B3F- cell Marine

Tanker Collision A1 The header stating – Maximum marine hull – should be rephrased into Marine Hull or equivalent, since the SF calculation in L2 (Oct 2011) text is based on a given tanker having the maximum sum of the three (Marine Hull + Marine Liability + Marine Oil Pollution Liability), not the maximum of the components of the sum.


Tanker Collision B1 The header stating – Maximum marine hull – should be rephrased into Marine Hull or equivalent, since the SF calculation in L2 (Oct 2011) text is based on a given tanker having the maximum sum




Deadline

20 January 2012

12:00 CET

of the three (Marine Hull + Marine Liability + Marine Oil Pollution Liability), not the maximum of the components of the sum.


Tanker Collision C1 The header stating – Maximum marine hull – should be rephrased into Marine Hull or equivalent, since the SF calculation in L2 (Oct 2011) text is based on a given tanker having the maximum sum of the three (Marine Hull + Marine Liability + Marine Oil Pollution Liability), not the maximum of the components of the sum.


Tanker Collision A2


Tanker Collision B2


Tanker Collision C2


Tanker Collision A3


Tanker Collision B3


Tanker Collision C3


Platform Explosion A5


Platform Explosion B5


Platform Explosion C5


Platform Explosion D5


Platform Explosion E5








Deadline

20 January 2012

12:00 CET

















SCR - B3F- cell Marine C9

SCR - B3F- cell Marine C11

SCR - B3F- cell Aviation A1

SCR - B3F- cell Aviation B1

SCR - B3F- cell Aviation A2 What should undertaking put here in case of an unlimited cover ?


SCR - B3F- cell Aviation A3


SCR - B3F- cell Fire A1



SCR - B3F- cell Liability A1

SCR - B3F- cell Liability B1

SCR - B3F- cell Liability C1




Deadline

20 January 2012

12:00 CET

SCR - B3F- cell Liability D1

SCR - B3F- cell Liability E1











SCR - B3F- cell Liability A4 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.

SCR - B3F- cell Liability B4 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.

SCR - B3F- cell Liability C4 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.

SCR - B3F- cell Liability D4 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.

SCR - B3F- cell Liability E4 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.





Deadline

20 January 2012

12:00 CET














SCR - B3F- cell Liability D8 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.








Deadline

20 January 2012

12:00 CET






SCR - B3F- cell Liability

D10






D12 The L2 text (Oct 2011) is not proposing any calculation rules for two liability scenarios, only the concept of number of liability claims has been introduced in addition to the risk factors and requirement of having gross earned premiums.



H12








Deadline

20 January 2012

12:00 CET

D14



H14

SCR - B3F- cell Credit &

Suretyship Large Credit

Default A1



Default B1



Default A2



Default B2



Default A4



Default B4



Default A5



Default B5


Suretyship Recession Risk

A7






Deadline

20 January 2012

12:00 CET

A8



A9



A10


Suretyship C12


Suretyship C14

SCR - B3F- cell Other non-

life catastrophe risk A1


life catastrophe risk B1


life catastrophe risk C1


life catastrophe risk D1


life catastrophe risk E1












life catastrophe risk H2




Deadline

20 January 2012

12:00 CET












life catastrophe risk H4

SCR - B3F- cell Mass

Accident A1


Accident B1


Accident C1


Accident D1


Accident E1


Accident F1


Accident G1


Accident H1


Accident I1


Accident J1





Deadline

20 January 2012

12:00 CET

Accident K1


Accident L1


Accident M1


Accident A2


Accident B2


Accident C2


Accident D2


Accident E2


Accident F2


Accident G2


Accident H2


Accident I2


Accident J2


Accident K2


Accident L2


Accident M2


Accident A3




Deadline

20 January 2012

12:00 CET


Accident B3


Accident C3


Accident D3


Accident E3


Accident F3


Accident G3


Accident H3


Accident I3


Accident J3


Accident K3


Accident L3


Accident M3


Accident A20


Accident B20


Accident C20


Accident D20





Deadline

20 January 2012

12:00 CET

Accident E20


Accident F20


Accident G20


Accident H20


Accident I20


Accident J20


Accident K20


Accident L20


Accident M20


Accident K22


Accident N22

SCR - B3F- cell

Concentration Accident A1

SCR - B3F- cell

Concentration Accident B1

SCR - B3F- cell

Concentration Accident C1

SCR - B3F- cell

Concentration Accident D1

SCR - B3F- cell

Concentration Accident E1

SCR - B3F- cell

Concentration Accident F1




Deadline

20 January 2012

12:00 CET

SCR - B3F- cell

Concentration Accident G1

SCR - B3F- cell

Concentration Accident H1

SCR - B3F- cell

Concentration Accident I1

SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell




Deadline

20 January 2012

12:00 CET


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell


SCR - B3F- cell

Concentration Accident J22

SCR - B3F- cell Pandemic

A1




Deadline

20 January 2012

12:00 CET


B1


C1


D1


E1


F1


A2


B2


C2


D2


E2


F2


A3


B3


C3


D3


E3





Deadline

20 January 2012

12:00 CET

F2


A20


B20


C20


D20


E20


F20


F21


D22


G22

SCR - B3G – General

SCR - B3G – Purpose

SCR - B3G – Benefits

SCR - B3G – Costs

SCR - B3G – Groups

SCR - B3G – Materiality

SCR - B3G - Disclosure

SCR - B3G – Frequency

SCR - B3G- cell A1

Can this be already found from some other template ?




Deadline

20 January 2012

12:00 CET

SCR - B3G- cell A2 See A1

SCR - B3G- cell A3 See A1.

SCR - B3G- cell A4

SCR - B3G- cell A5

The definition of the earned premium is incorrect. It claims that the whole written premium should be earned over the term of the policy. In the life insurance there often is, however, the deposit component which won't be earned. Wikipedia recognises the definition

A.1. Earned Premium

Earned premium is the portion of an insurance written premium which is considered

"earned" by the insurer, based on the part of the policy period that the insurance has been

in effect, and during which the insurer has been exposed to loss. … Earned premium will

not be returned to the insured if the policy is cancelled.

Why this information cannot be taken from the template Cover A1A, both templates will

be filled in yearly basis?

SCR - B3G- cell A6 See the comment in cell A5.





SCR - B3G- cell A11

SCR - B3G- cell A12

SCR - B3G- cell A13

It should be made clearer in the text of the template that only 30 % of the net Basic Solvency Capital requirement should be entered, not the full extent.

SCR - B3G- cell A14

SCR - B3G- cell A15 Is this the reporting requirement already ?

SCR - B3G- cell A16

http://en.wikipedia.org/wiki/Written_premium




Deadline

20 January 2012

12:00 CET

MCR - B4A & B4B – General It is currently unclear where annuities related to non-life contracts should be reported.

B22?

MCR - B4A & B4B – Purpose

MCR - B4A & B4B – Benefits

MCR - B4A & B4B – Costs

MCR - B4A & B4B – Groups

MCR - B4A & B4B –

Materiality

MCR - B4A & B4B -

Disclosure

MCR - B4A & B4B –

Frequency

MCR - B4A- cell A1

MCR - B4A- cell B2

MCR - B4A- cell C2

MCR - B4A- cell B3

MCR - B4A- cell C3

MCR - B4A- cell B4

MCR - B4A- cell C4

MCR - B4A- cell B5

MCR - B4A- cell C5

MCR - B4A- cell B6

MCR - B4A- cell C6

MCR - B4A- cell B7

MCR - B4A- cell C7

MCR - B4A- cell B8




Deadline

20 January 2012

12:00 CET

MCR - B4A- cell C8

MCR - B4A- cell B9

MCR - B4A- cell C9

MCR - B4A- cell B10

MCR - B4A- cell C10

MCR - B4A- cell B11

MCR - B4A- cell C11

MCR - B4A- cell B12

MCR - B4A- cell C12

MCR - B4A- cell B13

MCR - B4A- cell C13

MCR - B4A- cell B14

MCR - B4A- cell C14

MCR - B4A- cell B15

MCR - B4A- cell C15

MCR - B4A- cell B16

MCR - B4A- cell C16

MCR - B4A- cell B17

MCR - B4A- cell C17

MCR - B4A- cell A18

MCR - B4A- cell B19

MCR - B4A- cell B20

MCR - B4A- cell B21

MCR - B4A- cell B22

MCR - B4A- cell C23

MCR - B4A- cell A24




Deadline

20 January 2012

12:00 CET

MCR - B4A- cell A25

MCR - B4A- cell A26

MCR - B4A- cell A27

MCR - B4A- cell A28

MCR - B4A- cell A29

MCR - B4A- cell A30

MCR - B4A- cell A31

MCR - B4B- cell B1

MCR - B4B- cell C1

MCR - B4B- cell D2

MCR - B4B- cell E2

MCR - B4B- cell F2

MCR - B4B- cell G2

MCR - B4B- cell D3

MCR - B4B- cell E3

MCR - B4B- cell F3

MCR - B4B- cell G3

MCR - B4B- cell D4

MCR - B4B- cell E4

MCR - B4B- cell F4

MCR - B4B- cell G4

MCR - B4B- cell D5

MCR - B4B- cell E5

MCR - B4B- cell F5

MCR - B4B- cell G5

MCR - B4B- cell D6




Deadline

20 January 2012

12:00 CET

MCR - B4B- cell E6

MCR - B4B- cell F6

MCR - B4B- cell G6

MCR - B4B- cell D7

MCR - B4B- cell E7

MCR - B4B- cell F7

MCR - B4B- cell G7

MCR - B4B- cell D8

MCR - B4B- cell E8

MCR - B4B- cell F8

MCR - B4B- cell G8

MCR - B4B- cell D9

MCR - B4B- cell E9

MCR - B4B- cell F9

MCR - B4B- cell G9

MCR - B4B- cell D10

MCR - B4B- cell E10

MCR - B4B- cell F10

MCR - B4B- cell G10

MCR - B4B- cell D11

MCR - B4B- cell E11

MCR - B4B- cell F11

MCR - B4B- cell G11

MCR - B4B- cell D12

MCR - B4B- cell E12

MCR - B4B- cell F12




Deadline

20 January 2012

12:00 CET

MCR - B4B- cell G12

MCR - B4B- cell D13

MCR - B4B- cell E13

MCR - B4B- cell F13

MCR - B4B- cell G13

MCR - B4B- cell D14

MCR - B4B- cell E14

MCR - B4B- cell F14

MCR - B4B- cell G14

MCR - B4B- cell D15

MCR - B4B- cell E15

MCR - B4B- cell F15

MCR - B4B- cell G15

MCR - B4B- cell D16

MCR - B4B- cell E16

MCR - B4B- cell F16

MCR - B4B- cell G16

MCR - B4B- cell D17

MCR - B4B- cell E17

MCR - B4B- cell F17

MCR - B4B- cell G17

MCR - B4B- cell B18

MCR - B4B- cell C18

MCR - B4B- cell D19

MCR - B4B- cell F19

MCR - B4B- cell D20




Deadline

20 January 2012

12:00 CET

MCR - B4B- cell F20

MCR - B4B- cell D21

MCR - B4B- cell F21

MCR - B4B- cell D22

MCR - B4B- cell F22

MCR - B4B- cell E23

MCR - B4B- cell G23

MCR - B4B- cell A24

MCR - B4B- cell A25

MCR - B4B- cell A26

MCR - B4B- cell A27

MCR - B4B- cell A28

MCR - B4B- cell A29

MCR - B4B- cell A30

MCR - B4B- cell A31

MCR - B4B- cell B32

MCR - B4B- cell C32

MCR - B4B- cell B33

MCR - B4B- cell C33

MCR - B4B- cell B34

MCR - B4B- cell C34

MCR - B4B- cell B35

MCR - B4B- cell C35

MCR - B4B- cell B36

MCR - B4B- cell C36

MCR - B4B- cell B37




Deadline

20 January 2012

12:00 CET

MCR - B4B- cell C37

MCR - B4B- cell B38

MCR - B4B- cell C38

MCR - B4B- cell B39

MCR - B4B- cell C39

Assets - D1- General A mapping exercise will be required in order to match data types to the codes in the

CIC table. The definitions of data elements may vary across the EU so it will be

necessary to ensure that matching to CIC codes is carried out in a consistent way.

Could it be enough to report the ISIN-code only because it already includs lots of information like issuer sector, issuer group code etc. . Proportionality and materiality should be taken into account in reporting these issues. Do we need to report unit-linked products here at so detailed level? ? It might be better to have an own template for unit linked assets with less information.

Assets - D1- Purpose

Assets - D1- Benefits

Assets - D1- Costs

Assets - D1- Groups

Assets - D1- Materiality

Assets - D1- Disclosure

Assets - D1- Frequency

Assets – D1 – Quarterly

Exemption




Deadline

20 January 2012

12:00 CET

Assets - D1- cell A1









NACE codes are not readily available from current data sources for example,

Bloomberg. An exercise will be required to map issuers to NACE codes. There is a

risk of differences between the ways in which different entities complete this mapping.

This could be avoided if supervisors centrally created a mapping of issuers to NACE

codes rather than requesting this information via the QRTs.

Other code systems are currently used across Europe, such as ICB and GICS, this

makes the necessity for a mapping system even more essential.

There is a question as to whether a licence fee should be paid in order to use NACE

codes, in such cases, undertakings would be required to pay for the use of multiple

coding systems.


This information must be sourced from an external provider and will be difficult to

report unless the fund/issuer has provided their ultimate parent company information.

This is not always the case.

Group structures are frequently subject to change and to update this information will

be time consuming.

If ISIN codes have been used in cell A5 of this template, then the information will be

easily identifiable. Please refer to D1- cell A4 for CEA comments on the use of ISIN

codes.




Deadline

20 January 2012

12:00 CET


The large CIC classification matrix is difficult to maintain with a high accuracy, i.e. it increases the operational risk - still ambiguous, e.g. companies might classify differently, e.g. should 'Government Guaranteed belong to Government, Other or Corporate, Other




Any new asset classification system will involve tremendous administrative costs at

first, such codes would have to be entered manually for the current book of business.

Supervisory guidance is necessary to ensure all undertakings apply the codes in the

same way, for example it could be the case that the same security is assigned a

different CIC by different groups and undertakings. It could be the case that different

undertakings use other CIC codes for the same investment instruments. It would be

helpful if the CIC code is issued together with the ISIN codes or other codes used as a

result of reporting requirements. It would be useful to complete a mapping exercise

as outlined in D1- cell A9.

As it currently stands, the CIC does not seem to adequately distinguish between

different types of risk categories, primarily with bonds. Financials and Corporates as

well as Covered Bonds are all put into one asset group (Bonds- Corporate bonds),

subordinated bonds are not addressed as a single category. Additional categories

would be helpful, such as private equities. Furthermore, we suggest merging

commodities funds with alternative funds.

There is a need for a strong and stable reference frame, more precise definitions

should be provided for each category, especially concerning Investment Funds.

Clarification is also required as to what code would be used when the security is

unlisted.

We question the relevance of applying this to unit linked related securities from the

perspective of risk exposure monitoring, considering that the investment risk in not

supported by the undertaking.




Deadline

20 January 2012

12:00 CET

The information about the place where the security is listed combined with CIC code is too complex. Is these information really needed ? Does not ISIN-code be sufficient ? This will require changes in systems. And this is not risk-based, as solvency II should be.













Assets - D1Q- General

Assets - D1Q- Purpose

Assets - D1Q- Benefits

Assets - D1Q- Costs

Assets - D1Q- Groups

Assets - D1Q- Materiality

Assets - D1Q- Disclosure




Deadline

20 January 2012

12:00 CET

Assets - D1Q- Frequency

Assets - D1Q- cell A1 (list)























Assets - D1Q- cell A3





Deadline

20 January 2012

12:00 CET



Assets - D1Q- cell A7A



Assets - D1Q- cell A8C

Assets - D1Q- cell A8D


Assets - D1Q- cell A9B

Assets - D1Q- cell A9C

Assets - D1Q- cell A9D

Assets - D1Q- cell A9E

Assets - D1Q- cell A9F


Assets - D1Q- cell A10B






Assets - D1Q- cell L16

Assets - D1S- General

Assets - D1S- Purpose

Assets - D1S- Benefits

Assets - D1S- Costs




Deadline

20 January 2012

12:00 CET

Assets - D1S- Groups

Assets - D1S- Materiality

Assets - D1S- Disclosure

Assets - D1S- Frequency

Assets - D1S- cell A1














Assets – D2O- General Underlying assets in derivatives are not possible to derive in the report, e.g. there are 4 legs in an Fx-swap but only two fields to report. Is there a reason for this?

Assets – D2O- Purpose

Assets – D2O- Benefits

Assets – D2O- Costs

Assets – D2O- Groups

Assets – D2O- Materiality




Deadline

20 January 2012

12:00 CET

Assets – D2O- Disclosure

Assets – D2O- Frequency

Assets – D2O – Quarterly

Exemption

Assets - D2O- cell A1











Assets - D2O- cell A13 Derivatives can be used also in hedging of the liabilities e.g. the technical provisions.














Deadline

20 January 2012

12:00 CET











Assets - D2T- General To meet the purpose we do only see a need for active derivative positions to be able to have an understanding about the risk in the portfolio. Transaction doesn’t add any value if the receiver doesn’t have a portfolio system where this could be monitored (i.e. supervisor).

Assets - D2T- Purpose

Assets - D2T- Benefits

Assets - D2T- Costs

Assets - D2T- Groups

Assets - D2T- Materiality

Assets - D2T- Disclosure

Assets - D2T- Frequency

Assets – D2T– Quarterly

Exemption

Assets - D2T- cell A1





Deadline

20 January 2012

12:00 CET










Assets - D2T- cell A13 See comment in D2O – A13




















Deadline

20 January 2012

12:00 CET





Assets – D3- General This information is already reported in the annual report on a level more suitable for the industry. Double reporting should be avoided. Further clarification required: How different types of derivatives should be handled on this template.

Assets – D3- Purpose Investment systems calculate performance in original currencies. A conversion to reporting currencies where consideration is taken to currency hedges requires massive system changes.

Assets – D3- Benefits

Assets – D3- Costs

Assets – D3- Groups

Assets – D3- Materiality

Assets – D3- Disclosure

Assets – D3- Frequency






In the LOG stands: "Also applicable to derivatives generating interest flows" Where to report all other derivatives? Where the negative cash flows should be reported. See the comment in Template VA C2B – A1



Mark to market result would be more adequate to use from a supervisory perspective.




Deadline

20 January 2012

12:00 CET

Should the variation margin of derivatives, which are received or paid on a daily basis although

they are not sold or closed, report here. See the comment in the Template VA C2B – A7.

Assets – D4- General To receive information from Investment Funds will be a challenge, especially on a quarterly basis

and from Private Equity and Hedge Funds. There will be a lot of manual work involved with large risk of human errors. Timing issue will also be challenging especially for quarterly reporting. Furthermore, will the information received be sufficient? What about funds that has underlying exposure to other currencies? This will most likely not be captured within present structure. The requirement to report information on funds on a look through principle is extremely difficult and costly. Especially if this requirement is applicable also for the unit linked funds. Equality between fund owners! Information should be given not only to the insurance companies. .

Assets – D4- Purpose


Assets – D4- Costs The requirement to report information on funds on a look through principle is extremely difficult and costly.


Assets – D4- Materiality See CEA’s comment on this.


Assets – D4- Frequency Privat equity funds – quarterly impossible.

Assets – D4 – Quarterly

Exemption




Assets - D4- cell A4 Underlying asset category will be impossible to retrieve for some private equity funds.





Deadline

20 January 2012

12:00 CET


Column specifying the currency not only local /foreign .



Assets – D5- General
























Deadline

20 January 2012

12:00 CET


Assets – D6- General The use of cash is not properly addressed in this template.



























Deadline

20 January 2012

12:00 CET




TP - F1 & F1Q- General The sign notation has not been properly specified in the templates. It would be easier




TP - F1 & F1Q - Purpose

TP - F1 & F1Q - Benefits

TP - F1 & F1Q - Costs

TP - F1 & F1Q - Groups

TP - F1 & F1Q - Materiality

TP - F1 & F1Q - Disclosure

TP - F1 & F1Q - Frequency

TP - F1- cells A1 – A14

TP - F1- cell A7A

TP - F1- cell A7B

TP - F1- cell A7C

TP - F1- cells B1 – B14

TP - F1- cells B2 – C2

TP - F1- cells B4-C1

TP - F1- cells BA1 – BA13

TP - F1- cell BB1

TP - F1- cell BB10

TP - F1- cell BB13




Deadline

20 January 2012

12:00 CET

TP - F1- cells BC1 – BC13

Because of the definition of line BD this line has overlapping with line BD cash flows: with the additional resulting cash flows from the future premiums, expenses of the policies which would lapse without future premiums, difference of the expenses of active and paid-up policies, commissions. We question the usefulness of split in lines BC-BF and propose the requirements would be deleted. Wouldn't the future cash flows in template TP – F2 give even better information. Do the outward reinsurance premiums belong to here?

TP - F1- cells BD1 – BD13

Including the additional resulting cash flows from the future premiums this line seem to be EPIFP without the restrictions to positive HRG's. As mentioned in comments to line BC and BF this line has overlap with them. If the overlap is removed and only the future premiums are reported then this kind of information leaves it open the real impact of the future premiums. We question the usefulness of split in lines BC-BF and propose the requirements would be deleted. Wouldn't the future cash flows in template TP – F2 give even better information.

TP - F1- cells BF1 – BF13

Because of the definition of line BD this line has overlapping with line BD cash flows: with the additional resulting cash flows from the future premiums, e.g commissions from the unit-linked business. We question the usefulness of split in lines BC-BF and propose the requirements would be deleted. Wouldn't the future cash flows in template TP – F2 give even better information.

TP - F1- cells CB1 – CB14A CB9, CB14 should be formulas?

TP - F1- cells CC1 – CC14 CC9, CC14 should be formulas?

TP - F1- cells CD1 – CD14A CD9, CD14 should be formulas?

TP - F1- cells C1 – C14A

TP - F1- cells CB9A – C9A

TP - F1- cells E1 – E13 E10: something wrong in formulas F10 and F11, FB10 and FB11?

TP - F1- cells FB7A

TP - F1- cells FB7B

TP - F1- cells FB7C




Deadline

20 January 2012

12:00 CET

TP - F1- cells IA1 – IA 13 If TP is compared with the surrender values where the surrender values are reported?

TP - F1- cells J1 – JL13

TP - F1- cells M1-M13

TP - F1- cells N1-N13

TP - F1- cells O1-O13

TP - F1- cells P1-P13 What should be reported, paid claims and from which period or the net present value?

TP - F1- cells Q1-Q13

TP - F1Q- cells A1-A13

TP - F1Q- cell A7A

TP - F1Q- cell A7B

TP - F1Q- cell A7C

TP - F1Q- cells B1-B13

TP - F1Q- cells C1-C14A

TP - F1Q- cell C11

TP - F1Q- cell C12

TP - F1Q- cell C13

TP - F1Q- cell C14A

TP - F1Q- cell E1-E13

TP – F2- General Normal reserving method in non-life companies estimate total reserve levels. This approach would overhaul that general principle and would require drastic changes to methods currently used. This sheet might be of use for the supervisor if more close supervision is needed, e.g. if a company breaches some limits. The sign notation has not been properly specified in the templates. It would be easier







Deadline

20 January 2012

12:00 CET

TP – F2- Purpose

TP – F2- Benefits

TP – F2- Costs Non-life: So far the actuarial methods have been sufficient for reserve levels and worked very well. Changing to cash flow based approach requires considerable amounts of resources.

TP – F2- Groups

TP – F2- Materiality

TP – F2- Disclosure

TP – F2- Frequency

TP – F2- cells A1-A34

TP – F2- cells C1 – C35 This overlaps with column D.

TP -F2- cells D1-D35

Including the additional resulting cash flows from the future premiums this line seem to be EPIFP without the restrictions to positive HRG's. This line has overlap with C- and F-columns. If the overlap is removed and only the future premiums are reported then this kind of information leaves it open the real impact of the future premiums.

TP -F2- cells F1-F35 This overlaps with column D.

TP -F2- cells AU1 –AU35

TP -F2- cells CU1 – CU35 This overlaps with column DU.

TP -F2- cells DU1 – DU35

Including the additional resulting cash flows from the future premiums this line seem to be EPIFP without the restrictions to positive HRG's. This line has overlap with CU- and FU-columns. If the overlap is removed and only the future premiums are reported then this kind of information leaves it open the real impact of the future premiums.

TP -F2- cells FU1 – FU35 This overlaps with column DU.

TP -F2- cells I1 –I35

TP -F2- cells J1 –J35 See above




Deadline

20 January 2012

12:00 CET

TP -F2- cells K1 –K35 See above

TP -F2- cells L1 –L35 See above

TP -F2- cells M1 –M35

TP -F2- cells N1 –N35 See above

TP -F2- cells O1 –O35 See above

TP -F2- cells P1-P35 See above

TP -F2- cells Q1 –Q35

TP -F2- cells R1 –R35 See above

TP -F2- cells S1 –S35 See above

TP -F2- cells T1 –T35 See above

TP -F2- cells U1 – U35

TP -F2- cells CH1 –CH35 See above

TP -F2- cells DH1 –DH35 See above

TP -F2- cells FH1 –FH35 See above

TP -F2- cells V1 –V35

TP -F2- cells X1 – X35 See above

TP -F2- cells Y1-Y35 See above

TP -F2- cells Z1- Z35 See above

TP -F2- cells GH1 –GH35

TP – F3- General

The LOG comment specifies that annuities stemming from NL contracts are excluded

however the definition for cell A1 states that for non-life annuities, it should be

specifies which product it belongs to. This seems to be inconsistent. The template

should not include information of non-life annuities.

TP – F3- Purpose

We think this template shall not be included in the set of templates. Arguments:

We very much doubt whether this template is good for the stated purpose. There may be thousneds of HRG's (see comment in cell A2B) and much more lines. None will read the template, neither the preparer nor the users. Even though HRG's would be defined




Deadline

20 January 2012

12:00 CET

properly there might be several tens of lines which is far too granular. For the preparer this template will not give any more risk awerness because the risks are revealed by other means. We think that it is same for the supervisor, too, which must study more than one company. Neiher this template is good to the supervisor for making summaries over the undertakings because each undertaking will define HRG in different ways and thus the temlpates of different undertakings are not comprable.

TP – F3- Benefits See the comment for the purpose. Cost of benefits is not proper. This will require from the preparers lot of programming work. The runs of Pilar I measurements are already very heavy and this will load the runs further. The programming and run times and computer resources are already now the main restrictive factor, for many improvements of the processes. The time and resources used to this template can be ued much more resource effectively.

TP – F3- Costs

TP – F3- Groups




TP - F3- cell A1

LOB is not mentioned in the list of different characters. There are hybrid products where the policyholder can choose the yield to be guaranteed or unit linked.

TP - F3- cell A2A

TP - F3- cell A2B

HRG is specified for this cell. However, HRG is not specified L1 standard and L2 draft standard. This is totally wrong place to give such an important definition. HRG are used for many needs in the standards. There is a partial definition of HRG in L2 draft standard in Article 28(2) and 29 but they apply only to life insurance and cases where groupin is made. More seriously, those definitions are in




Deadline

20 January 2012

12:00 CET

contradicton with the definition given for this template. L3 standard cannot overcome L2 standard and thus it cannot be contradictionary with L2. The definition of HRG must be given in L2 standard. After that it must be checked that all the requirements connected to HRG's workable. (This should be the comment for L2 standard and thus this is wrong place.) Clearer title would be Number of HRG's in Product. The current title makes to understand that HRG's are listed and numbered and the number of that list is reported even though the definition is enough specified but also the title could be more.

TP - F3- cell A2C If the definition of L2 is followed the only possible answer is No.

TP - F3- cell A3

TP - F3- cell A4

TP - F3- cell A5

TP - F3- cell A6

TP - F3- cell A7

Regular but flexible premium is very important class of premium paying but not included in this list.

TP - F3- cell A8

TP - F3- cell A9

TP - F3- cell A10

TP - F3- cell A15

TP - F3- cell A21

TP - F3- cell A24

Capital at risk is reinsurance dependent (eg. Article 106(2)(a)) and reinsurance may be undertaking specific, not product or contract specific, so that this information may be difficult to issue. Better information would be sum at risk.

TP - F3- cell A26

TP - F3- cell A30

TP - F3- cell A34A

The definition in the LOG is not unambiguous.




Deadline

20 January 2012

12:00 CET

This is not calculated by model because it is not used anywhere else. It is not good use of resources to use programming time and resources to this figure which is too granular. Many factors which are used for the HRG classification are not relevant to the thoretical claims and thus unnesessary. There is no cell A20 to which the comparision is done.

TP - F3- cell A41

TP – F3A- General

TP – F3A- Purpose

TP – F3A- Benefits

TP – F3A- Costs

TP – F3A- Groups

TP – F3A- Materiality

TP – F3A- Disclosure

TP – F3A- Frequency

TP - F3A- cell A1

TP - F3A- cell A2

TP - F3A- cell A3

TP - F3A- cell A4

TP - F3A- cell A5

TP - F3A- cell A6

TP - F3A- cell A7

TP - F3A- cell A8

TP - F3A- cell A9

TP - F3A- cell A10

TP - F3A- cell A11




Deadline

20 January 2012

12:00 CET

TP - F3A- cell A12

TP - F3A- cell A13

TP - F3A- cell A14

TP - F3A- cell A15

TP - F3A- cell A16

TP - F3B- cell A1

TP - F3B- cell A2

TP - F3B- cell A3

TP - F3B- cell A4

TP - F3B- cell A5

TP - F3B- cell A6

TP - F3B- cell A7

TP - F3B- cell A8

TP - F3B- cell A9

TP - F3B- cell A10

TP – F4- General According to LOG the released annuity claims provisions (and annuity IBNR) do not fit to any column A0-A5. There seems to be missing a column for “Undiscounted annuity provisions released during year N” It is understandable, that the relating non-life line of business would give information to where such annuities arise. However, such information may prove out to be difficult as additional field to database should be needed. More details should be assigned to how the number of annuities, average technical rate in year N, the average duration of the obligations and weighted average age of beneficiaries are calculated. Is the age for example the age of beneficiaries at the date of report (for example 31.12.2015), or at the date of accident, or another definition?




Deadline

20 January 2012

12:00 CET

It is required to modify existing systems to calculate the annuity claims provisions set up during year N, as the value should correspond to the date of setting up the reserve. At least at the beginning it should be allowed to value such annuities as the end of year N.

TP – F4- Purpose

TP – F4- Benefits

TP – F4- Costs

TP – F4- Groups




TP - F4- cell A0

TP - F4- cell A1 Where to put undiscounted annuity claims provisions released during year N?

TP - F4- cell A2

TP - F4- cell A3

TP - F4- cell A4

TP - F4- cell A5

TP - F4- cell B1

TP - F4- cell C1

TP - F4- cell D1

TP - F4- cell A6

TP – E1 & E1Q- General

TP – E1 & E1Q - Purpose

TP – E1 & E1Q - Benefits




Deadline

20 January 2012

12:00 CET

TP – E1 & E1Q - Costs

TP – E1 & E1Q - Groups

TP – E1 & E1Q - Materiality

TP – E1 & E1Q - Disclosure

TP – E1 & E1Q - Frequency

TP - E1- cells A1-P1

TP -E1- cellss A2-L2


TP -E1- cellss M4-P4

TP -E1- cellss A5-P5


TP -E1- cellss M7-P7


TP -E1- cells A10-P10



TP -E1- cells A14-L14

TP -E1- cells A15-L15

TP -E1- cells M16-P16










Deadline

20 January 2012

12:00 CET






We would need costly changes in the recovery process, pricing and related systems if we must separate the recourse and any recovery cash flows from the cash flows. We do the pricing based on the “net” cash flows (not splitting cash flows to out- and in-flows itself or splitting aforementioned two cash-flows to sub-groups as well).








The life template does not include a requirement to report on the use of simplified

methods. should be deleted also from the non-life templates!




Localisation of risk will be difficult to split out, in the same way that data on technical

provisions are not available by counterparty. We would ask that this requirement be

removed (see CEA note). For example marine insurance.

TP - E1 Q- cells A1-R1





Deadline

20 January 2012

12:00 CET





TP – E2- General Normal reserving method in non-life companies estimate total reserve levels. This approach would overhaul that general principle and would require drastic changes to methods currently used. This sheet might be of use for the supervisor if more close supervision is needed, e.g. if a company breaches some limits.

TP – E2- Purpose

TP – E2- Benefits

TP – E2- Costs So far the actuarial methods have been sufficient for reserve levels and worked very well. Changing to cash flow based approach requires considerable amounts of resources. If in and out cash flows are required separately, it will involve substantial costs for us.

TP – E2- Groups

TP – E2- Materiality

TP – E2- Disclosure

TP – E2- Frequency

TP - E2- cells A1-A31

TP - E2- cells B1-B31

TP - E2- cells C1-C31

TP - E2- cells D1-D31

TP - E2- cells E1-E31

TP - E2- cells F1-F31

TP – E3- General It is unclear if and how annuities should be included in this template. We suggest dropping the




Deadline

20 January 2012

12:00 CET

salvage and subrogation triangle for paid claims. We suggest to aggregate them with paid claims. There is no additional value from separation (materiality!). For RBNS claims, these are reserved taking salvage etc into account when relevant, but no split of « gross reserve » and « salvage reserve » exists and would have to be done using keys. We do not see any advantages in doing so. As the purpose should not be for auditing, the template could be for a standard 10 years, and left empty for those years there is not data available, for short tailed lines. The claim adjustment expenses we do not currently report with the claims payments, and we do not have this information per accident year (or uw year for that matter), i.e. a process and system change would be needed. We could not get the historical data in any way, when doing reporting the first time We have the “net” triangles of the claim payments, not the split into the 3 first triangles. What would be the specific supervisory purpose of the split? We use endogenous inflations mainly, which may specific per HRGs. Then you would also need the triangles per HRGs, which we certainly do not recommend. A simple yes/no answer could be sufficient at the top of the page. The methods used, and tail factor, is also per HRG, or even several methods within one HRG, so it must be thought about the optimal way to gather this information, if at all. We believe it is perhaps too detailed. Reporting RBNS claims should not be required as RBNS and IBNR are calculated as

whole. (See CEA note for more details)

Should be included the cell to show whether AY or UWY is used.

TP – E3- Purpose

TP – E3- Benefits

TP – E3- Costs

TP – E3- Groups





Deadline

20 January 2012

12:00 CET



TP - E3- cells A00

TP - E3- cells A01

TP - E3- cells A02

TP - E3- cells A03: N

TP - E3- cells A04

TP - E3- cells A1-A15-J0

It should be better defined what ot include in J0, J16 and J32. Cumulative or non cumulative amounts of N-15 and prior years? The use of J0 in columns “In current year” and “Sum of years” is contradictory.

TP - E3- cells A17-A31-J16 We cannot split out salvage and subrogation due to limitations in our base systems.

TP - E3- cells A33-A47-J32

TP - E3- cells P1-P15-J0

TP - E3- cells P33-P47-J32

TP - E3- cells AE1-AE15-J0

1. The RBNS claims are reserved case by case when the claim is estimated to exceed a predefined treshold. The claims under yhis treshold are not reserved since it would not enhance the reserving process and accuracy. The table will then increase costs but not increase teh level of reserve accuracy. 2. The accident year approach suites best for the Non-life insurance since the reserving accuracy is more dependent on claim year than the contract entering year. 3. More guidance is needed to handle portfolio transfers.



TP - E3- cells IH1-IE15B

TP – E4- General This is not consistent with Solvency II reserving process. Does not give any information, especially in short-tailed business.




Deadline

20 January 2012

12:00 CET

This template is overly ambitions and burdensome to create. All base systems do not support open and closed codes, and certainly not reopening codes. For a claim occurring in the current accident year, the claim could be closed and reopened during the same year and it would be impossible to split the payments into paid on closed and reopened claims. The entire form is based upon the assumption that one can distinguish open from closed claims, thus the usability of this report is highly dependent on the reserving process and systems in place; if a case reserve with a standard reserve is used, then the number of claims and closed/open status are relevant. But if such a process is not used and/or not supported by the systems, the number of claims data has poor quality even if it was available. In addition to this, there are lobs, like workers comp or other personal lines, where it is impossible to close a claim. We also feel that the form is too detailed, and it should not be necessary to split on open, closed and reopened claims. The template implies a connection between each individual claim in the base system and the corresponding amount booked in general ledger. (e.g. column 17) This connection does not exist today, and the history is not possible to recreate. Currency: We suggest doing the entire template in converted currency. Accident year/underwriting year: Insurance information by accident year and reinsurance by underwriting year then capturing the nature of the contracts and cover periods.

TP – E4- Purpose The number of reopened claims is very low and therefore the systematic follow upp haven't been necessary in order to increase the visibility or accuracy of reserving. Also the definition of closed claim may not be systematic between company's and therefore the comparability is poor and information marginal to the reserving process. See CEA comments. Filling the template should not be required in countries where RBNS reserving and classifying claims to open/closed/reopened is not commonly used.

TP – E4- Benefits The allocation of open and reopen claims is not enhancing the reserving process since the number of reopen claims is very low and therefore the information is not used in the reserving.




Deadline

20 January 2012

12:00 CET

TP – E4- Costs Systematic follow-up of reopened claims will then be costly compared to benefits obtaint.

TP – E4- Groups




TP - E4- cells A1-A10

TP - E4- cells B1-B10

TP - E4- cells C1-C10

TP - E4- cells D1-D10

TP - E4- cells E1-E10

TP - E4- cells F1-F10

TP - E4- cells G1-G10

TP - E4- cells H1-H10

TP - E4- cells I1-I10

TP - E4- cells J1-J10

TP - E4- cells K1-K10

TP - E4- cells L1-L10

TP - E4- cells M1-M11

TP - E4- cells N1-N11

TP - E4- cells O1-O11

TP - E4- cells P1-P10

TP - E4- cells Q1-Q10

TP - E4- cells R1-R10

TP - E4- cells S1-S10

TP - E4- cells T1-T10




Deadline

20 January 2012

12:00 CET

TP – E6- General It should be sufficient with 10 accident years in this template. Other comments re this item are that the data is not readily available from all countries/systems. For example, some systems use average claim and do not have any well defined small reserve amount per claim. So we can only use the paid amount for losses that are not yet closed. Also, in other systems, only claims above some threshold are stored individually from some reporting claim systems. This means that finding the payment amount per claim for smaller claims as at Dec 31st can be difficult, as this information is generally only recorded for the larger losses. Hence, if the claim size categories start below threshold, there can be problems finding the exact numbers in the first categories. Some systems do not record case estimates, hence we can only use the payments to assess the claim size. Whereas in other systems where, in general, all open claims have a case reserve associated, and we can find the reported incurred claim cost (paid+case) for them. This means that the definition of “claim cost per loss” can be different for various systems and countries. Since all the figures should be reported in reporting currency, the appropriate currency rates must be applied. Finding the exact time of transaction for all paid amounts can be tricky from some systems/countries, so the amounts in reporting currency will be subject to some uncertainty. Some definitions must be made for this template to make sense, e.g., should zero-claims be counted? What currency principles to use? Should case estimates be added to the claim cost, and if so, from which countries/systems? The allocation of collective reserve to each bands doesn't enhance the reserving process or solvency assesment. Although without the allocation of collective reserve this distribustion doesn't give the correct insight to company's claim distribution. Clarification required for certain aspects: How should outstanding claims be valued? Should the reserves be discounted? Should they be at their best estimate or case estimate? Should the risk




Deadline

20 January 2012

12:00 CET

marginal also be considered? Should inflation be assessed with older claims? Accident year (AY) based reporting should be allowed. (also in LOG!) What is the expected outcome for this template for supervisors?

TP – E6- Purpose

TP – E6- Benefits

TP – E6- Costs

TP – E6- Groups




TP – E6- cells A1-A20

TP – E6- cells B1-B20

TP – E6- cells C1-C20

TP – E6- cells D1-D20

TP – E6- cells E1-E20

TP – E6- cells F1-F20

TP – E6- cells G1-G20

TP – E6- cells H1-H20

TP – E6- cells I1-I20

TP – E6- cells J1-J20

TP – E6- cells K1-K20

TP – E6- cells L1-L20

TP – E6- cells AE1-AE20

TP – E6- cells AF1-AF20




Deadline

20 January 2012

12:00 CET

TP – E7A- General

TP – E7A- Purpose The required extra claims for each line of business are not significant for the listing since some insurance lines doesn't incude major individual risks.

TP – E7A- Benefits

TP – E7A- Costs Costly for the mass insurance lines where the peak risks are not defined but are handled with special rating.

TP – E7A- Groups

TP – E7A- Materiality

TP – E7A- Disclosure

TP – E7A- Frequency

TP – E7A- cell A1

TP – E7A- cell B1

TP – E7A- cell C1

TP – E7A- cell D1

TP – E7A- cell E1

TP – E7A- cell F1

TP – E7A- cell G1

TP – E7A- cell H1

TP – E7A- cell I1

TP – E7A- cell J1

TP – E7A- cell K1

TP – E7A- cell L1

TP – E7A- cell M1

TP – E7B- General Filling this template requires tremendous amount of work. For example Other motor insurance-LoB the Sum insured (SI) is a function of time (the value of vehicles are reduced as they are aged). SI is found in core systems for some LoB:s only, thus for several LoB:s individual approximate-




Deadline

20 January 2012

12:00 CET

based models should be build. The usefullness of the information is highly questionable, as this does not take into account of the propability of the maximum loss occurring.

The sum insured hasn't beed evaluated in mass insurance lines where special rating is used

(for exemple home full value insurance). The risks is handled with special rating and

classification factors. The evaluation of each sum insured will lead to inconsistency

between company's results and will unnecessarily burden the tariff process if done during

pricing. The following requirements are especially difficult and costful to obtain compared to the questionable benefits:

A policy cover comprising a number of buildings across the country must be broken down.

An overall cover which can not be seen as a single underwriting risk must be broken down.

In case of joint liability through co-insurance, the part belonging to a defaulting co-insurer must be included in the sum insured as well.

TP – E7B- Purpose Should be filled only for large risk lines where the sum insured evaluation is a tarif factor.

TP – E7B- Benefits

TP – E7B- Costs

TP – E7B- Groups

TP – E7B- Materiality

TP – E7B- Disclosure

TP – E7B- Frequency

TP – E7B- cell A01

TP – E7B- cell A1

TP – E7B- cell B1




Deadline

20 January 2012

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TP – E7B- cell C1

TP – E7B- cell D1 The sum insured hasn't beed evaluated in mass insurance lines where special rating is used (for example home full value insurance). The risks are handled with special rating and classification factors. The evaluation of each sum insured will lead to inconsistency between company's results.

TP – E7B- cell E1

Re - J1- General We query the supervisory purpose of requesting only LOBs with facultative risks, if the

purpose is to evaluate the vulnerability of a single risk event, we propose to report the

10 largest single risks covered with facultative reinsurance. Definition of FAC: Are Reverse Flow and Co-reinsurance programs with Limit/SI/EML for single client exceeding Treaty limit or totally outside treaty, to be regarded as facultative reinsurance and be included in this section?

The term Facultative generally means reinsurance for one single risk as opposed to treaty which is reinsurance of portfolio. Facultative reinsurance is also commonly used as a mechanism in industrial insurance in various risk sharing solutions. These situations are because the client wishes to share the risk, and not because the “risk doesn’t fit into the regular policy acceptance of the insurance company “. Clarification needed if also captive and coinsurance risks are intended.

Re - J1- Purpose

Re - J1- Benefits

Re - J1- Costs

Re - J1- Groups

Re - J1- Materiality

Re - J1- Disclosure

Re - J1- Frequency

Re - J1- cell A00

Re - J1- cell A1




Deadline

20 January 2012

12:00 CET

Re - J1- cell B1

Re - J1- cell C1

Re - J1- cell D1

Re - J1- cell E1

Re - J1- cell F1

Re - J1- cell G1

Re - J1- cell H1

Re - J1- cell I1

Re - J1- cell J1

Re - J1- cell K1

Re - J1- cell L1

Re - J1- cell M1

Re - J1- cell N1

Definitions in LOG are too detailed, for example EML:

The Solvency II statement (LOG document) is not compatible with the way in which we calculate a fire EML for properties. The essential difference is that we do not take in to account all factors likely to lessen the extent of the loss. For example, in our EML estimates no allowance is made of active fire protection systems, such as sprinkler protection. Taking in to account all factors likely to lessen the extent of the loss would be more consistent with our Normal Loss Expectancy (NLE) assessment. To the best of our knowledge, our method of assessing the fire loss potential to property at a site is consistent with property loss assessment techniques used by all property insurance companies. Although the terms EML and NLE may vary between companies, the disregard of active protection systems is a fundamental aspect of the EML assessment.

Re - J1- cell P1

Re - J1- cell Q1




Deadline

20 January 2012

12:00 CET

Re - J1- cell W1

Re - J1- cell Y1

Re - J1- cell Z1

Re - J1- cell AB1 Remove “reinsurance” from the definition in LOG document to make it clearer.

Re - J1- cell AC1

Re - J1- cell A01

Re - J1- cell A11

Re - J1- cell B11

Re - J1- cell C11

Re - J1- cell D11

Re - J1- cell E11

Re - J1- cell F11

Re - J1- cell G11

Re - J1- cell H11

Re - J1- cell I11

Re - J1- cell J11

Re - J1- cell K11

Re - J1- cell L11

Re - J1- cell M11

Re - J1- cell O11

Re - J1- cell U11

Re - J1- cell W11

Re - J1- cell X11

Re - J1- cell Z11

Re - J1- cell AA11

Re – J2- General Referring to treaties in the LOG document – is this really what should be reported in this template or is it all ceded reinsurance?




Deadline

20 January 2012

12:00 CET Shall all ceded business be included irrespective of the size of the portfolio/risk ceded?

Reinsurance treaties are not purchased so that 2014 treaties can be reported fully in 2013. Only estimates. 20% materiality threshold is reasonable, however depending of the size of the treaty in question, as individual treaties may be insignificant. Rather overall 20% change. Report contains information that is not available in reinsurance systems and has to be manually added. As this is an extensive report it should contain information that is readily available in systems. Are risks/policies that are reinsured to captives or fronted to other insurance companies considered as program or facultative placements? Reporting “when needed” means quartelly.

Re – J2- Purpose

Re – J2- Benefits

Re – J2- Costs There will be a lot of added costs if all needed data has to be added to reinsurance system (e.g. progressive sections, progressive number and quantity of surplus/layers in program, EIOPA codes and names of Reinsured, Reinsurer and Broker, Type of treaty, Catastrophic guarantees specifications).

Re – J2- Groups

Re – J2- Materiality

Re – J2- Disclosure

Re – J2- Frequency

Re - J2- cell A1

Re - J2- cell B1

Re - J2- cell C1




Deadline

20 January 2012

12:00 CET

Re - J2- cell D1

Re - J2- cell E1

Progressive number of surplus/layer in program only works for simple structures, as only the excess point and limit in combination with program share will define the position of an agreement in a reinsurance program. Common rules need to be specified to assign numbering of surplus/layer in program.

Re - J2- cell F1

Re - J2- cell G1

Re - J2- cell H1

How should treaties that include several LoB’s be reported. E.g. Event covers usually cover both FOP, MAT, MOC etc.

Re - J2- cell I1

Re - J2- cell J1

Re - J2- cell K1

Re - J2- cell L1

Re - J2- cell M1

Re - J2- cell N1

Re - J2- cell O1 See comment to Re - J1 cell N1.

Re - J2- cell P1

Re - J2- cell Q1

Re - J2- cell R1

Re - J2- cell S1

Re - J2- cell T1

Re - J2- cell U1

Re - J2- cell V1

Re - J2- cell W1

Re - J2- cell X1

Re - J2- cell Y1

Re - J2- cell Z1

Re - J2- cell AA1 What is the distinction between reinsurance commission and overriding commission?




Deadline

20 January 2012

12:00 CET

Re - J2- cell AB1 What is the distinction between reinsurance commission and overriding commission?

Re - J2- cell AC1

Re - J2- cell AD1

Re - J2- cell AE1

Re - J2- cell AF1

Re - J2- cell AG1

Re - J2- cell AM1

Re - J2- cell AO1

Re - J2- cell AP1

Re - J2- cell AQ1

Re – J3- General

Re – J3- Purpose

Re – J3- Benefits

Re – J3- Costs

Re – J3- Groups

Re – J3- Materiality

Re – J3- Disclosure

Re – J3- Frequency

Re - J3- cell A1

Re - J3- cell B1

Re - J3- cell C1

Re - J3- cell D1

Better definitions needed. Some companies use the same legal entity for both direct insurance (=insurer) and assumed treaty reinsurance (=reinsurer).

Re - J3- cell E1

Re - J3- cell F1




Deadline

20 January 2012

12:00 CET

Re - J3- cell G1

Re - J3- cell H1

Re - J3- cell I1

Re - J3- cell J1

Re - J3- cell L1

Re - J3- cell M1

Re - J3- cell O1

Re - J3- cell P1

Re - J3- cell Q1

Re - J3- cell R1

SPV - General

SPV - Purpose

SPV - Benefits

SPV - Costs

SPV - Groups

SPV - Materiality

SPV - Disclosure

SPV - Frequency

SPV- cell A1

SPV- cell B1

SPV- cell B1A

SPV- cell C1

SPV- cell D1

SPV- cell E1

SPV- cell F1




Deadline

20 January 2012

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SPV- cell F1A

SPV- cell G1

SPV- cell H1

SPV- cell I1

SPV- cell J1

SPV- cell K1

SPV- cell L1

SPV- cell M1

SPV- cell N1

SPV- cell O1

SPV- cell P1

SPV- cell Q1

SPV- cell R1

SPV- cell S1

SPV- cell T1

SPV- cell V1

SPV- cell W1

SPV- cell X1

SPV- cell Y1

SPV- cell Z1

G01-Purpose A mix of SII and IFRS items in this report.

G01-Benefits

G01-Costs

G01-Application

G01-Materiality

G01-Disclosure




Deadline

20 January 2012

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G01-Frequency

G01- cell A1

G01- cell B1

G01- cell C1

G01- cell D1

G01- cell E1

G01- cell F1

G01- cell G1

G01- cell H1

G01- cell I1

G01- cell J1

How is underwriting performance defined. Is it related to the Variation analysis

disclosed under VA-C2C?

G01- cell K1

G01- cell L1

J1+K1 will not equal L1 because taxes and other "other" items will only be included in

L1.

Further clarification needed. LOG!

How is „Total performance“ defined. Is this related to Profit before tax (IFRS) or is this

in any way related to VA-templates.

G01- cell M1

G01- cell N1

G01- cell O1

G01- cell P1

G01- cell Q1

G01- cell R1

G01- cell S1




Deadline

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12:00 CET

G01- cell T1

G01- cell U1

G01- cell V1

G03 & G04-Purpose

G03 & G04-Benefits

G03 & G04-Costs

G03 & G04-Application

G03 & G04-Materiality

G03 & G04-Disclosure

G03 & G04-Frequency

G03- cell A1

G03- cell B1

G03- cell C1

G03- cell D1

G03- cell E1

G03- cell F1

G03- cell G1

G03- cell H1

G03- cell I1

G03- cell J1

G03- cell K1 LOG: Definition is not correct – only copied from cell J1.

G03- cell L1

G03- cell M1

G03- cell N1

G03- cell O1

G03- cell P1




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G04- cell A1

G04- cell A2

G04- cell B1

G04- cell C1

G04- cell D1

G04- cell E1

G14-Purpose

G14-Benefits

G14-Costs

G14-Application

G14-Materiality

G14-Disclosure

G14-Frequency

G14- cell A1

G14- cell B1

G14- cell C1

G14- cell D1

G14- cell E1

G14- cell F1

G14- cell G1

G14- cell H1

G14- cell I1

G14- cell J1

G14- cell K1

G14- cell L1

G14- cell M1




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G14- cell N1

G14- cell O1

G14- cell P1

G14- cell Q1

G14- cell R1

G20-Purpose

G20-Benefits

G20-Costs

G20-Application

G20-Materiality

G20-Disclosure

G20-Frequency

G20- cell A1

G20- cell B1

G20- cell C1

G20- cell D1

G20- cell E1

G20- cell F1

G20- cell I1

G20- cell J1

G20- cell K1

IGT1 to IGT4-Purpose

IGT1 to IGT4-Benefits

IGT1 to IGT4-Costs

IGT1 to IGT4-Application

IGT1 to IGT4-Materiality




Deadline

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IGT1 to IGT4-Disclosure

IGT1 to IGT4-Frequency

IGT1- cell B6

IGT1- cell C6

IGT1- cell D6

IGT1- cell E6

IGT1- cell F6

IGT1- cell G6

IGT1- cell H6

IGT1- cell I6

IGT1- cell J6

IGT1- cell K6

IGT1- cell L6

IGT1- cell M6

IGT1- cell N6

IGT1- cell O6

IGT1- cell P6

IGT1- cell Q6

IGT1- cell R6

IGT1- cell S6

IGT2- cell B6

IGT2- cell C6

IGT2- cell D6

IGT2- cell E6

IGT2- cell F6

IGT2- cell G6




Deadline

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IGT2- cell H6

IGT2- cell I6

IGT2- cell J6

IGT2- cell K6

IGT2- cell L6

IGT2- cell M6

IGT2- cell N6

IGT2- cell O6

IGT2- cell P6

IGT2- cell Q6

IGT2- cell R6

IGT2- cell S6

IGT2- cell T6

IGT2- cell U6

IGT2- cell V6

IGT2- cell W6

IGT3- cell B6

IGT3- cell C6

IGT3- cell D6

IGT3- cell D6

IGT3- cell E6

IGT3- cell F6

IGT3- cell G6

IGT3- cell H6

IGT3- cell I6

IGT3- cell J6




Deadline

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IGT3- cell K6

IGT3- cell L6

IGT3- cell M6

IGT3- cell N6

IGT3- cell O6

IGT4- cell B5

IGT4- cell C5

IGT4- cell D5

IGT4- cell E5

IGT4- cell F5

IGT4- cell G5

IGT4- cell H5

IGT4- cell I5

IGT4- cell J5

IGT4- cell K5

IGT4- cell L5

IGT4- cell M5 Should be M6: Clarification of LOG needed. What value should be reported?

IGT4- cell N5

IGT4- cell O5

IGT4- cell P5

RC-Purpose

RC-Benefits

RC-Costs

RC-Application

RC-Materiality

RC-Disclosure What does simplified version mean?




Deadline

20 January 2012

12:00 CET

RC-Frequency

RC- cell A2

RC- cell A3

RC- cell A4

RC- cell A5

RC- cell A6

RC- cell A7

RC- cell A8

RC- cell A9

RC- cell A10

RC- cell A11

RC- cell A12

RC- cell A13

What is the SII value of the exposure? Clarification needed? Is this applicable for

reinsurance?

RC- cell A14 Could USD be a group currency in EU?

RC- cell A15

Definition is not clear e.g. What is max value for a derivative? Is this only applicable

for reinsurance?

RC- cell A16

RC- cell A17

RC- cell A18

Documents

Deadline 20 January 2012 12:00 CET...Deadline 20 January 2012 12:00 CET will decrease the overview of the Balance sheet. BS-C1- cell L6C Technical Provisions should not be divided